Code of Alabama

Ala. Code § 13A-5-9.1 (2026)

Retroactive Application of Section 13A-5-9.

✓ official Alabama Legislature (ALISON) text, current July 2026
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Repealed by Act 2014-165, §1, effective March 13, 2014.

(Act 2001-977, 3rd Sp. Sess., p. 941, §1; Act 2007-457, p. 945, §1.)

Notes of Decisions
Cited in 81 cases (4 in the last 5 years), 2004–2026 · leading case: Holt v. State, 960 So. 2d 726 (Ala. Crim. App. 2006).
Holt v. State, 960 So. 2d 726 (Ala. Crim. App. 2006). · cites it 72× “William Buster Holt appeals the circuit court's denial of his motion made pursuant to § 13A-5-9.1, Ala.Code 1975, to reconsider his sentence of life imprisonment without the possibility of parole imposed upon application of the Habitual Felony Offender Act ("HFOA") for his 1987…”
Ex Parte State, 960 So. 2d 740 (Ala. 2006). · cites it 42× “Moreover, I write specially because I believe that § 13A-5-9.1, Ala.Code 1975, may well violate the separation-of-powers provisions of the Alabama Constitution as a legislative incursion into the power reserved to the judiciary.”
Ex Parte Gunn, 993 So. 2d 433 (Ala. 2007). · cites it 28× “, petition, which Gunn concedes was actually a second motion for reconsideration of his sentence under § 13A-5-9.1, Ala. Code 1975. The trial court dismissed Gunn's petition on the basis that, under Wells v.”
Ex parte K.R., 210 So. 3d 1106 (Ala. 2016). · cites it 14× “In Ex parte Knight, a petitioner, Knight, filed a motion for sentence reconsideration under Ala.Code 1975, § 13A-5-9.1, and Kirby v. State, 899 So.”
Ex Parte Butler, 972 So. 2d 821 (Ala. 2007). · cites it 21× “In March 2005, Butler filed a motion pursuant to § 13A-5-9.1, Ala.Code 1975, asking the trial court to reconsider his sentences and to resentence him to life imprisonment with the possibility of parole.”
Ex parte Robert Gill., 157 So. 3d 881 (Ala. 2014). · cites it 45× “I would grant inmate Robert Gill's petition for a writ of certiorari to review the Court of Criminal Appeals' affirmance of the trial court's denial of Gill's motion for sentence reconsideration filed pursuant to § 13A-5-9.1, Ala. Code 1975. Gill v. State (No.”
Ex Parte Sandifer, 925 So. 2d 290 (Ala. Crim. App. 2005). · cites it 26× “In 2004, Sandifer moved that his sentence be reduced pursuant to § 13A-5-9.1, Ala.Code 1975 — the recent amendment to the HFOA.”
Ashford v. State, 12 So. 3d 160 (Ala. Crim. App. 2008). · cites it 24× “Jerry Ashford appeals from the denial of this, at least his sixth, if not seventh, [1] motion to reconsider his sentence, made pursuant to § 13A-5-9.1, Ala.Code 1975. On August 27, 1992, Ashford was convicted of robbery in the first degree and was sentenced as a habitual…”
Ex Parte Jenkins, 992 So. 2d 1248 (Ala. 2007). · cites it 12× “Code 1975, the Habitual Felony Offender Act (the "HFOA"), as amended by § 13A-5-9.1, Ala.Code 1975. We reverse and remand.”
Knight v. State, 92 So. 3d 717 (Ala. 2011). · cites it 28× “This Court granted certiorari review to consider the validity of an administrative order of the Montgomery Circuit Court pursuant to which a circuit judge was appointed to decide James Sheridan Knight’s motion for sentence reconsideration filed under Ala.Code 1975, § 13A-5-9.1,…”
Butler v. State, 972 So. 2d 817 (Ala. Crim. App. 2006). · cites it 15× “Lacy Ray Butler appeals the circuit court's denial of his motion made pursuant to § 13A-5-9.1, Ala.Code 1975, to reconsider his sentences of life imprisonment without the possibility of parole imposed upon application of the Habitual Felony Offender Act (the "HFOA") for his…”
Turner v. State, 51 So. 3d 394 (Ala. Crim. App. 2010). · cites it 11× “2007), Jenkins filed two motions for sentence reconsideration pursuant to § 13A-5-9.1, Ala.Code 1975, see Kirby v. State, 899 So.”
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