California Supreme Court Refuses to Rule on Constitutionality of Miller Fix, Giving Juveniles Sentenced to Life Parole after 25 Years
On May 26, 2016, the California Supreme Court issued a ruling which passed on a chance to rule on the constitutionality of the state legislature's response to the United States Supreme Court's decision in Miller v. Alabama which prohibited mandatory life sentences for Juvenile offenders. California's new post-Miller law grants a parole hearing to juvenile offenders after serving 25 years, at which time the parole board is required to "give great weight to the diminished culpability of juvenile as compared to adults."
The case before the state's high court was that of 21-year-old Tyris Franklin who, when he was 16 in 2011, killed another 16-year-old boy. Charged with first degree murder, Franklin was found guilty at trial and given two 25-year consecutive sentences -- one for the murder and one for a firearm enhancement. Soon after Franklin was sentenced, the U.S. Supreme Court decided Miller (132 S. Ct. 2455), which held that mandatory life sentences for juvenile offenders unconstitutional.
On appeal, Franklin argued his 50-year sentence was equivalent to a life sentence under Miller and that his sentence was therefore infirm. While Franklin's appeal was pending the California state legislature passed its "Miller-fix" law, which granted juveniles sentenced to life parole eligibility after serving 25 years and directs the parole board to give extra consideration to juveniles in favor of release when considering "any subsequent growth and increased maturity" since they were sentenced.
The court of appeals affirmed Franklin's conviction and sentence, ruling that the intervening change in the law granting parole eligibility after 25 years mooted Franklin's Miller claim, and thus his sentence was "no longer the functional equivalent of an LWOP sentence."
Franklin took his appeal to the California Supreme Court, who also affirmed the sentence but remanded for a hearing to allow Franklin "the opportunity to make a record of information that will be relevant to the Board" when it considers Franklin's release.
In affirming the sentence, the Supreme Court said that in light of the legislative fix to Miller, which gives Franklin the "realistic possibility" of release after 25 years, "Franklin's sentence is not functionally equivalent to life without parole" and his constitutional, challenge to his sentence was rendered moot.
However, because Miller was not decided at the time Franklin was sentenced, the trial court saw no reason to allow him the chance to offer evidence to mitigate his otherwise automatic 50-year sentence. The Supreme Court thus remanded the case for the purpose of allowing Franklin to make such a record that can be used at any future parole hearing. See: The People v. Franklin, No. S217699 (S. Ct. CA), May 26, 2016.
Related legal case
Miller v. Alabama
| Year | 2016 |
|---|---|
| Cite | 132 S.Ct. 2455 |
| Level | Supreme Court |
| Conclusion | Bench Verdict |
| Injunction Status | N/A |