## Facts

- Carroll F. Youngblood was convicted in Texas state court of aggravated sexual abuse, and the jury assessed life imprisonment and a $10,000 fine.
- After direct appeal affirmance, Youngblood sought state habeas relief, arguing Texas law did not authorize both imprisonment and a fine for the offense and that prior state precedent required a new trial.
- A state habeas court recommended granting relief based on then-existing precedent.
- Before the Texas Court of Criminal Appeals acted, the Texas Legislature enacted Article 37.10(b), authorizing appellate courts to “reform” an improper verdict assessing punishment not authorized by law.
- Applying Article 37.10(b) to Youngblood’s case, the Texas Court of Criminal Appeals deleted the unauthorized fine and denied a new trial.
- Youngblood filed a federal habeas petition contending that applying Article 37.10(b) retroactively violated the Ex Post Facto Clause.
- The federal district court denied relief; the Fifth Circuit reversed, concluding the retroactive change eliminated a substantial protection (the asserted right to a new trial).
- The Supreme Court granted certiorari.

## Issues

1. Whether retroactive application of a statute allowing appellate reformation of an unauthorized punishment, rather than ordering a new trial, violates the Ex Post Facto Clause.
2. What definition of “ex post facto law” governs evaluation of retroactive criminal-law changes, including changes characterized as procedural.

## Decision

- The Supreme Court reversed the Fifth Circuit and held that applying Article 37.10(b) to Youngblood did not violate the Ex Post Facto Clause.
- The Court treated Teague v. Lane as nonjurisdictional and reached the merits because the State did not invoke Teague.
- The Court reaffirmed the traditional Beazell definition of ex post facto laws and rejected broader formulations based on “substantial protections,” “modes of procedure,” or general “disadvantage” to the accused.
- Article 37.10(b) was a procedural mechanism for correcting an unlawful portion of a sentence on appeal; as applied, it reduced the judgment by striking the fine and did not alter the elements of the offense or proof of guilt.
- The Ex Post Facto Clause does not give a defendant a vested right to a particular remedy (such as a new trial) when the legislature changes the method of correcting sentencing error.
- To the extent prior decisions suggested that retroactive procedural changes are ex post facto whenever they disadvantage the defendant, those statements were disapproved insofar as inconsistent with Beazell.

## Legal Principles

- An ex post facto law is one that (1) criminalizes previously innocent conduct, (2) increases the punishment for a crime after its commission, or (3) deprives the accused of a defense available when the act was committed.
- The Ex Post Facto Clause targets retroactive changes to the definition of crimes, punishments, or available defenses, not every retroactive procedural change.
- A retroactive procedural change that alters how a judgment or sentence is corrected, without increasing punishment or removing a defense, does not violate the Ex Post Facto Clause.
- A defendant has no constitutional entitlement to a specific postconviction remedy when the legislature alters the remedial procedure for correcting legal error.

## Conclusion

The Court held that Texas could apply Article 37.10(b) retroactively to delete an unauthorized fine without granting a new trial because the change was procedural and did not criminalize prior innocent conduct, increase punishment, or remove a defense, and it reaffirmed Beazell as the controlling test for ex post facto analysis.


Collins v. Youngblood, 497 U.S. 37 (1990)