Ex Parte Madden

Bobby Wayne Madden pleaded guilty to, and was convicted of, one count of burglary, one count of rape, and two counts of sodomy, all in the first degree. At the sentencing hearing, the State presented evidence of three prior felony convictions in Georgia. Madden was sentenced under the Habitual Felony Offender Act, Ala. Code 1975, § 13A-5-9, to life imprisonment without the possibility of parole.

Madden appealed from his sentence to the Court of Criminal Appeals. He argued that he had been improperly sentenced under the Habitual Felony Offender Act. Specifically, he argued that the trial court…