In Bishop v. State, 344 So. 3d 906 (Ala. Crim. App. 2021), this Court recognized that the post-release supervision referred to in § 13A-5-6(c) is in the nature of probation and that § 15-20A-20(d) sets out the manner in which that post-release supervision must be served. However, the fact that ASORCNA sets out the manner in which post-release supervision must be served does not answer the question whether retroactive application of § 13A-5-6(c) is constitutionally permissible.

Nevertheless, the Court of Criminal Appeals has repeatedly held that a petitioner is not entitled to respond. See Jenkins v. State, 105 So. 3d 1234, 1244-45 (Ala. Crim. App. 2011) ; Mashburn v. State, 148 So. 3d 1094, 1113-15 (Ala. Crim. App. 2013) ; Mays v. State, 233 So. 3d 1010, 1016 (Ala. Crim. App. 2016) ; Price v. State, 278 So. 3d 1287, 1289 (Ala. Crim. App. 2018) ; Bishop v. State, 344 So.3d 906 (Ala. Crim. App. 2021). Those decisions ultimately relied on this Court's decision in Ex parte Ward, 46 So. 3d 888 (Ala. 2007).

§ 15-20A-4(27), Ala. Code 1975. See also Bishop v. State, 344 So. 3d 906, 915 (Ala. Crim. App. 2021). We note that the circuit court did not impose periods of post-release supervision on Colburn’s convictions for first-degree rape.

§ 15-20A-4(27), Ala. Code 1975. See also Bishop v. State, 344 So. 3d 906, 915 (Ala. Crim. App. 2021). Thus, we must remand this case for the circuit court to impose the required periods of post-release supervision on Johnson’s convictions for first-degree sodomy.