In a significant ruling, the Alaska Court of Appeals decided on October 2, 2026, that changes made to the state's presumptive sentencing laws in 2013 cannot be applied retroactively. This decision affects defendants like Yako William Collins, who were sentenced for crimes committed before these changes were enacted. The court's ruling emphasizes the importance of protecting defendants from retroactive laws that could increase their sentences.
The case, Collins v. State (Docket A-12816), centers around Collins, who was convicted of first-degree sexual assault in 2009. He was sentenced to 25 years in prison, with five years suspended. Collins sought a referral to a three-judge panel to potentially receive a lesser sentence based on mitigating factors. However, the sentencing judge denied this request, leading Collins to appeal the decision.
Initially, the Alaska Court of Appeals ruled in favor of Collins, allowing him to seek a referral to the three-judge panel. This ruling was based on the understanding that the legislature had increased the presumptive sentencing ranges for sexual felonies in 2006, which was intended to apply to defendants convicted after that change. However, in response to the court's ruling, the Alaska legislature passed a law in 2013 that explicitly barred defendants from seeking referrals based on certain mitigating factors identified in the previous ruling.
Upon reconsideration, the superior court concluded that the 2013 law eliminated the grounds on which Collins could seek a lesser sentence. Collins then appealed again, arguing that applying the 2013 changes to his case would violate the ex post facto clause of the Alaska Constitution, which prohibits retroactive application of laws that increase punishment.
The court ruled that the ex post facto clause does indeed prohibit the retrospective application of the 2013 changes to the presumptive sentencing statutes. Judge Mannheimer, writing for the court, stated, "The ex post facto clause prohibits retrospective application of the legislature's 2013 changes to the presumptive sentencing statutes." This ruling means that Collins must be sentenced under the law as it existed before the 2013 amendments.
The court's decision reinforces the principle that changes in the law cannot adversely affect individuals who committed offenses before those changes were enacted. This ruling is significant for Collins and others in similar situations, as it ensures that they will not face increased sentences due to legislative changes made after their crimes were committed.
Looking ahead, this ruling has implications for how sentencing laws are interpreted and applied in Alaska. It sets a precedent that protects defendants from retroactive changes that could increase their sentences, reinforcing the importance of the ex post facto clause in the state's legal framework. The decision may also influence future cases involving similar issues of legislative changes and their applicability to past offenses.
As for what comes next, it is unclear whether the state will appeal this ruling to a higher court. However, the Alaska Supreme Court has already weighed in on related issues in the past, making it unlikely that they would take up the case again unless new legal questions arise. For now, Collins is entitled to pursue a renewed application for referral to the three-judge panel based on the previous legal standards.