Bates was sentenced to life in prison for armed burglary and armed robbery. This was an enhanced habitual-offender sentence based in part on a drug conviction from 1990. Bates alleges that his attorney in the 1990 proceeding erroneously told him that this offense could not be used to enhance his sentences in future criminal cases, prompting him to plead guilty to the drug charge. He sought to overturn his 1990 conviction, but the First District Court declined to grant him relief.