Collins v. Youngblood

Youngblood (defendant) was convicted and sentenced to life imprisonment plus a $10,000 fine, though Texas law did not authorize a fine in addition to imprisonment for his offense; after a habeas court initially granted relief voiding his conviction, the Texas Legislature enacted a new law letting appellate courts reform improperly imposed sentences, and the appellate court used it to simply remove the unauthorized fine rather than grant a new trial. Youngblood then sought federal habeas relief, arguing the retroactively applied reformation law violated the Ex Post Facto Clause; the district court denied relief, and the court of appeals reversed.