The California Supreme Court clarified that a sentence need not exceed life expectancy to deprive a juvenile nonhomicide offender of the requisite meaningful opportunity for release based on demonstrated maturity and rehabilitation, remanding a 50-year and a 58-year sentence for resentencing.
The Idaho Supreme Court concluded that a discretionary fixed-life sentence violated Miller and Montgomery where the sentencing court heard no evidence of the mitigating factors of youth and made only brief, general reference to the defendant’s age at sentencing.
State v. Riley is a Connecticut Supreme Court case addressing whether Miller applies in a discretionary regime.
In 2015, the Connecticut Supreme Court decided in State v. Riley, 110 A.3d 1205 (Conn. 2015), that Miller’s holding extends to both lengthy term-of-years sentences that are the functional equivalent of life without parole and life-without-parole sentences imposed in a discretionary regime. A trial court may not impose discretionary life without parole (or the functional equivalent of life without parole) without first giving mitigating effect to the defendant’s youth and its attendant circumstances. The record must clearly reflect the court considered these factors before imposing the sentence. The court also noted that there is a presumption against imposing a life-without-parole sentence on a juvenile without first overcoming it with evidence of unusual circumstances.