Ex parte Joshua Lashawn Booth PETITION FOR WRIT OF CERTIORARI TO THE COURT OF CRIMINAL APPEALS (In re: Alabama Department of Corrections v. Joshua Lashawn Booth) (Bibb Circuit Court: CV-22-900034; Court of Criminal Appeals: CR-2023-0426).

CourtSupreme Court of Alabama
DecidedDecember 6, 2024
DocketSC-2024-0259
StatusPublished

This text of Ex parte Joshua Lashawn Booth PETITION FOR WRIT OF CERTIORARI TO THE COURT OF CRIMINAL APPEALS (In re: Alabama Department of Corrections v. Joshua Lashawn Booth) (Bibb Circuit Court: CV-22-900034; Court of Criminal Appeals: CR-2023-0426). (Ex parte Joshua Lashawn Booth PETITION FOR WRIT OF CERTIORARI TO THE COURT OF CRIMINAL APPEALS (In re: Alabama Department of Corrections v. Joshua Lashawn Booth) (Bibb Circuit Court: CV-22-900034; Court of Criminal Appeals: CR-2023-0426).) is published on Counsel Stack Legal Research, covering Supreme Court of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ex parte Joshua Lashawn Booth PETITION FOR WRIT OF CERTIORARI TO THE COURT OF CRIMINAL APPEALS (In re: Alabama Department of Corrections v. Joshua Lashawn Booth) (Bibb Circuit Court: CV-22-900034; Court of Criminal Appeals: CR-2023-0426)., (Ala. 2024).

Opinion

Rel: December 6, 2024

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is printed in Southern Reporter.

SUPREME COURT OF ALABAMA OCTOBER TERM, 2024-2025

_________________________

SC-2024-0259 _________________________

Ex parte Joshua Lashawn Booth

PETITION FOR WRIT OF CERTIORARI TO THE COURT OF CRIMINAL APPEALS

(In re: Alabama Department of Corrections

v.

Joshua Lashawn Booth)

(Bibb Circuit Court: CV-22-900034; Court of Criminal Appeals: CR-2023-0426)

MENDHEIM, Justice. SC-2024-0259

Joshua Lashawn Booth petitioned this Court for a writ of certiorari

to review the Court of Criminal Appeals' decision in Alabama

Department of Corrections v. Booth, [Ms. CR-2023-0426, Feb. 9, 2024]

___ So. 3d ___ (Ala. Crim. App. 2024), reversing the Bibb Circuit Court's

judgment ordering the Alabama Department of Corrections ("ADOC") to

calculate the correctional incentive time due to Booth. We granted

certiorari review to consider whether the Court of Criminal Appeals'

decision is in conflict with Ex parte Culbreth, 966 So. 2d 910 (Ala. 2006),

and Ex parte Tanksley, 418 So. 2d 94 (Ala. 1982); we conclude that it is.

As a result, we reverse the Court of Criminals Appeals' decision and

remand this cause to the Court of Criminal Appeals for proceedings

consistent with this opinion.

Facts and Procedural History

In 2018, Booth was convicted of three counts of possession of

obscene material, violations of § 13A-12-192, Ala. Code 1975, and was

sentenced to 15 years of imprisonment. While incarcerated at the Bibb

Correctional Facility in the custody of ADOC, Booth filed, on June 30,

2022, what he styled as an "application for a writ of habeas corpus" in the

Bibb Circuit Court, naming ADOC, among others, as a respondent. In

2 SC-2024-0259

his filing, Booth stated that "[t]his is a correctional incentive time case"

and alleged that ADOC "refused and [is] refusing to afford … Booth

correctional incentive time" under the applicable statutes. Specifically,

Booth argued that, although § 14-9-41(e), Ala. Code 1975, bars a person

who "has been convicted of a sex offense involving a child as defined in

[§] 15-20A-4(26)[, Ala. Code 1975,]" from receiving correctional incentive

time, that statute does not apply to convictions for possession of obscene

material, because, Booth argued, the possession-of-obscene-material

statute "refers to persons under the age of 17, not under 12." On August

25, 2022, ADOC filed a motion to dismiss Booth's filing or, in the

alternative, requested that a summary judgment be entered in its favor.

Booth filed a response to ADOC's motion on the same day.

On October 31, 2022, the Bibb Circuit Court conducted a hearing

and, following that hearing, entered an order directing the parties to file

additional briefing. On November 22, 2022, ADOC filed its ordered brief

and supporting material. On November 28, 2022, Booth filed a response

to ADOC's brief. On March 22, 2023, the Bibb Circuit Court entered an

order denying ADOC's motion to dismiss or, in the alternative, for a

summary judgment. In its order, the Bibb Circuit Court stated that "[t]he

3 SC-2024-0259

question to be resolved in this case is whether Joshua Lashawn Booth

should be getting correctional incentive time. He should." The Bibb

Circuit Court's order then analyzed the relevant statutes at issue, as they

existed at the times relevant to Booth's filing, and concluded that they

"did not and do[] not bar a person convicted of possession of obscene

material under Ala. Code [1975,] § 13A-12-192(b)[,] from the benefit of

incentive good time."

On April 12, 2023, Booth filed a motion for a judgment on the

pleadings or for a summary judgment based on the Bibb Circuit Court's

March 22, 2023, order. On April 26, 2023, Booth filed a renewed motion

for a summary judgment, arguing that an additional summary-judgment

hearing was not necessary because one had been held on ADOC's initial

summary-judgment motion. On May 3, 2023, the Bibb Circuit Court

granted Booth's renewed motion for a summary judgment, ordering that

the Bibb Circuit Court "[c]lerk's office … provide an updated transcript

to [ADOC] directing [it] to calculate the correctional incentive 'good' time

as due to … Booth …." ADOC appealed the Bibb Circuit Court's

judgment to the Court of Criminal Appeals.

4 SC-2024-0259

On appeal, ADOC noted that Booth's initial filing in this case had

been labeled an application for a writ of habeas corpus, which, ADOC

argued, is not the proper legal mechanism to challenge ADOC's decision

to deny Booth correctional incentive time. ADOC argued, for the first

time on appeal, that, instead of filing an application for a writ of habeas

corpus in the Bibb Circuit Court, Booth should have filed a petition for a

writ of certiorari in the Montgomery Circuit Court to challenge ADOC's

decision denying Booth correctional incentive time. The Court of

Criminal Appeals agreed with ADOC and reversed the Bibb Circuit

Court's judgment. See Alabama Dep't of Corr. v. Booth, [Ms. CR-2023-

0426, Feb. 9, 2024] ___ So. 3d ___ (Ala. Crim. App. 2023). In so doing, the

Court of Criminal Appeals stated:

"Recently, in Cook v. Alabama Department of Corrections, 390 So. 3d 1167 (Ala. Crim. App. 2023), a published order, this Court addressed a scenario nearly identical to this one. In that case, Cook, like Booth, filed a habeas petition in the Morgan Circuit Court challenging the ADOC's refusal to afford him correctional-incentive time. Although the ADOC did not challenge the venue in the circuit court or on appeal, this Court explained:

" 'It is well settled that this Court must treat an action according to its substance and not its style. See Ex parte Deramus, 882 So. 2d 875 (Ala. 2002). Although styled as a petition for a writ of habeas corpus, Cook was challenging the [A]DOC's 5 SC-2024-0259

decision to prohibit him from earning correctional incentive good time. There is no liberty interest in earning good time. See Collins v. Alabama Dep't of Corr., 982 So. 2d 1078 (Ala. 2007). The Alabama Supreme Court has held that a writ of certiorari filed in the Montgomery Circuit Court is the proper means by which an inmate may challenge the [A]DOC's decision regarding an inmate's ability to earn good time. Ex parte Boykins, 862 So. 2d 587 (Ala. 2002) (holding that a petition for a writ of certiorari is the proper means by which an inmate may challenge the [A]DOC's decision that an inmate is not entitled to good time). See also Ex parte Woods, 941 So. 2d 259 (Ala.

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Ex parte Joshua Lashawn Booth PETITION FOR WRIT OF CERTIORARI TO THE COURT OF CRIMINAL APPEALS (In re: Alabama Department of Corrections v. Joshua Lashawn Booth) (Bibb Circuit Court: CV-22-900034; Court of Criminal Appeals: CR-2023-0426)., Counsel Stack Legal Research, https://law.counselstack.com/opinion/ex-parte-joshua-lashawn-booth-petition-for-writ-of-certiorari-to-the-court-ala-2024.