Ala. Code
Code of Alabama

Ala. Code § 15-22-27.2 (2026)

Parole of Persons Sentenced to Life Imprisonment Upon Second Convictions of Class a Felonies.

✓ official Alabama Legislature (ALISON) text, current July 2026
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In all cases where a criminal defendant has been convicted of a Class A felony committed after a previous conviction of another Class A felony, and such second conviction results in a sentence to imprisonment for life, he shall not be eligible for parole.

(Acts 1977, No. 640, p. 1088.)

Notes of Decisions
Cited in 7 cases (1 in the last 5 years), 1984–2026 · leading case: State v. Thomas, 611 So. 2d 472 (Ala. Crim. App. 1992).
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State v. Thomas, 611 So. 2d 472 (Ala. Crim. App. 1992). · cites it 13× “Although the petitioner was sentenced to life imprisonment he is not eligible for parole pursuant to Ala.Code 1975, § 15-22-27.2, which provides: "In all cases where a criminal defendant has been convicted of a Class A felony committed after a previous conviction of another…”
Martin v. Alabama Bd. of Pardons & Paroles, 597 So. 2d 214 (Ala. Civ. App. 1992). · cites it 8× “Appellant, Tommy Lee Martin, filed a complaint for declaratory judgment against the Alabama Board of Pardons and Paroles (Board) in the Circuit Court of Montgomery County, seeking an order declaring him eligible for consideration for parole in spite of restrictions of Ala.Code…”
Goldsmith v. Alabama Bd. of Pardons & Paroles, 724 So. 2d 80 (Ala. Crim. App. 1998). · cites it 6× “Under the HFOA, a defendant convicted of a Class A felony with one prior Class A felony (or Class B or C felony) conviction could only be ‘punished by imprisonment for life or for any term of not more than 99 years but not less than 15 years.”
Moore v. State, 739 So. 2d 536 (Ala. Crim. App. 1998). · cites it 6× “1992), in which this court held that the HFOA did “implicitly and effectively repeal[] § 15-22-27.2 to the extent that § 15-22-27.”
Fowler v. State, 448 So. 2d 477 (Ala. Crim. App. 1984). · cites it 3× “Pursuant to § 15-22-27.2, Code of Alabama 1975, and because of Appellant’s having been previously convicted of a Class A felony, this was a sentence to life imprisonment without parole.”
Mullins v. Alabama Bd. of Pardons & Paroles, 711 So. 2d 1019 (Ala. Civ. App. 1997). · cites it 2× “See Ala.Code 1975, § 15-22-27.2 (criminal defendants convicted of a Class A felony committed after a previous conviction of another Class A felony shall not be eligible for parole).”
In re: Altonio Spencer v. State of Alabama, No. SC-2024-0672 (Ala. May 15, 2026). · cites it 2× “See Ala. Code 1975, § 15-22-27.1. Another prohibits parole for repeat Class A felons sentenced to imprisonment for life.”
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