Grantham v. State

On October 23, 1984, the Alabama Court of Criminal Appeals announced its decision in Alexander v. State, 475 So.2d 625 (Ala.Crim.App. 1984), which, contrary to prior holdings of that court, held that the failure of an inmate on a work release program to return to his place of employment constitutes escape from custody under § 13A-10-31, Code of Alabama (1975).

We granted Alexander's petition for certiorari; he argued that the new interpretation of the escape statute, adopted for the first time by the Court of Criminal Appeals, deprived him of due process if retroactively applied to him. This…