Lewis v. State

Robert Lewis was convicted of first-degree robbery in 1983 and was sentenced as a habitual felony offender to life imprisonment without the possibility of parole. See § 13A-5-9(c)(3), Ala.Code 1975. This Court affirmed his conviction and sentence on direct appeal. Lewis v. State, 465 So.2d 1185 (Ala.Crim.App.1984).

At the time Lewis was convicted, § 13A-5-9(c)(3), Ala.Code 1975, a part of Alabama’s “Habitual Felony Offender Act” (“the HFOA”), provided for a mandatory sentence of life imprisonment without the possibility of parole for a conviction of a Class A felony offense where the “criminal…