Mitchell v. Kelley (Per Curiam)Annotate this Case
After a jury trial, Appellant was found guilty of kidnapping, rape, and first-degree battery. Appellant was sentenced as a habitual offender to consecutive terms of imprisonment for life, life, and forty years. The Supreme Court affirmed. Appellant later filed a petition for writ of habeas corpus, arguing, among other things, that the judgment was illegal on its face because the trial court lacked authority to sentence him to terms of life imprisonment because he was under the age of twenty-one when he committed the offenses. The circuit court denied the petition. The Supreme Court affirmed, holding (1) Graham v. Florida did not apply to Appellant because he did not allege that he was under the age of eighteen when he committed the offenses; and (2) as to Appellant’s remaining claims, he did not establish the facial invalidity of the judgment in his case or the lack of jurisdiction by the trial court, and therefore, he did not show that he was entitled to relief.