Oyler v. Boles

William Oyler (defendant) and Paul Crabtree (defendant) were sentenced to life imprisonment under West Virginia’s habitual-criminal statute, which required courts to impose a mandatory life sentence upon a defendant’s third conviction of a crime punishable by incarceration. Prosecutors could choose to invoke the habitual-criminal statute by filing an information after a defendant was convicted but before the sentence was imposed. For example, Oyler was adjudicated in juvenile court three times for crimes that were punishable by incarceration. In 1953, Oyler was convicted of second-degree murder, and West Virginia’s normal statutory sentencing range for second-degree murder was five to 18 years of incarceration. From 1940 to 1955, Oyler was the only person sentenced as a habitual offender at Oyler’s local circuit court although five other men were eligible for a habitual-offender sentence at that court during that time, and all of the other eligible men had prior adult convictions. Oyler and Crabtree presented statistical data based on prison records showing that at least 904 men in West Virginia could have been sentenced as habitual offenders but were not. The West Virginia Supreme Court of Appeals denied Oyler’s and Crabtree’s petitions for writs of habeas corpus. The United States Supreme Court granted certiorari and consolidated Oyler’s and Crabtree’s cases. Oyler and Crabtree argued that prosecutors’ decisions to pursue habitual-offender sentences in only some of the eligible cases violated the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution.