INTRODUCTION Jeffrey Seagle is one of four men in the Alabama prison system who challenged a special form of life without the possibility of parole. (1) Seagle was not sentenced to life without parole by a jury or a judge. Instead, his possibly interminable prison sentence was given by the Alabama Community Notification Act (CNA). (2) Seagle, a convicted rapist, was rearrested at the end of his sentence because he was unable to provide a valid "actual" address, which the October 2005 version of the Alabama CNA required within forty-five days prior to release in order for a convicted sex offender to be allowed to reenter society. (3)