Juvenile Life Sentences
Facts: Defendant received a mandatory life sentence for a murder committed with he was sixteen years old. Defendant argued that “an automatic sentence of life imprisonment (with release no sooner than fifty-one years) is unconstitutional for a juvenile” based on the decisions in Roper v. Simmons, 543 U.S. 551 (2005), Graham v. Florida, 560 U.S. 48 (2010), and Miller v. Alabama, 567 U.S. 460 (2012).
Appellate Decision: The intermediate court rejected the Defendant’s argument that his life sentence was unconstitutional based on its prior decisions in other cases.
Review Granted: September 16, 2020.
Prediction: Ben thinks the Tennessee Supreme Court will vacate the life sentence as a direct violation of U.S. Supreme Court precedent. The next question will be the appropriate remedy. Ben thinks the Court will remand for a sentencing hearing at which the trial court will have the discretion to impose a sentence with a minimum of the lower end for a Class A felony and a maximum of life, since the U.S. Supreme Court has only held automatic life sentences to be unconstitutional for juveniles. David agrees but suggests a more elegant solution is to find the 1995 law (mandating no release for 51 years) as applied to juveniles is unconstitutional and then impose the earlier 1989 law allowing parole eligibility after a minimum of 25 years.