Brief Amicus Curiae of the Criminal Justice Legal Foundation in Support of Respondent
Criminal Justice Legal Foundation
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Summary

As a sentence eligibility factor, “irreparable corruption” or “permanent incorrigibility” would be unconstitutionally vague.

2020 | Federal Juristiction

Brief Amicus Curiae of the Criminal Justice Legal Foundation in Support of Respondent

Keywords permanently incorrigible; Eighth Amendment (U.S.); LWOP; life without parole; Miller; Due Process Clause (U.S.)
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Summary of Argument

The essential facts of this case are summarized in the oral ruling of the trial judge on resentencing, in the Joint Appendix (J. A.), and additional information is available in the opinions of the Mississippi courts. At the age of 15, petitioner Brett Jones left the home of his mother and stepfather in Florida and was taken in by his grandfather, Bert Jones, in Mississippi “to provide him with a home away from the circumstances in Florida.” J. A. 151-152. The circumstances included behavior by the stepfather that was abusive but short of “ ‘beatings, per se’ or any injuries that required medical attention.” Jones v. State, 285 So. 3d 626, ¶ 7, 630 (Miss. Ct. App. 2017) (Jones III) (appeal from post Miller hearing). Two months later, Jones stabbed his grandfather to death. Ibid., ¶ 8.

“A fair consideration of the evidence indicates that the killing of Mr. Bert Jones was particularly brutal.” J. A. 150. Jones stabbed his grandfather eight times, using a second knife after the first broke. He attempted to conceal the act. Ibid. Postmortem examination found defensive wounds on the grandfather’s hands. Jones v. State, 938 So. 2d 312, ¶ 10, 315 (Miss. Ct. App. 2006) (Jones I, initial appeal).

At trial, Jones claimed self-defense, and the jury was instructed on that defense and the lesser-included offense of manslaughter. The jury’s verdict of guilty of deliberate-design murder constitutes a finding “beyond a reasonable doubt that the defendant did not act in self-defense,” J. A. 150, rejecting Jones’s version of the circumstances of the killing. There is “no evidence of mistreatment or threat by Bert Jones, except the self defense claim asserted and rejected by the jury.” J. A. 151.

51.2 Jones was convicted of murder and sentenced to life imprisonment, and the judgment was affirmed on direct appeal. See 938 So. 2d, ¶ 11, at 315, ¶ 22, 317. The trial court subsequently denied post-conviction relief, and the Court of Appeals affirmed. Jones v. State, 122 So. 3d 725, ¶ 9, 729, ¶ 68, 742 (Miss. Ct. App. 2011), affirmed in part and reversed in part by Jones v. State, 122 So. 3d 698 (Miss. 2013) (Jones II).

This Court decided Miller v. Alabama, 567 U. S. 460 (2012) the following year. The Mississippi Supreme Court then granted certiorari limited to the Miller issue. Jones II, 122 So. 3d, ¶ 3, at 699. The Mississippi Supreme Court held that Miller was retroactive on collateral review. See id., ¶¶ 11-12, at 702. It vacated the sentence and remanded to the trial court for resentencing. See id., ¶ 29, at 703.

On resentencing, the trial judge noted the defendant’s age and his family situation. J. A. 151. The judge evidently did not find that situation to be as violent as petitioner would have this Court believe. Compare ibid., with Brief for Petitioner 7.

The judge stated expressly that he had “considered each of the Miller factors” and found that Jones was not entitled to have his sentence reduced “to make him eligible for parole consideration.” J. A. 152. The Court of Appeals affirmed. See Jones III, 285 So. 3d, ¶ 1, at 627. The Mississippi Supreme Court, a nine-justice court with a “rule of four,” granted certiorari, but then the court dismissed the writ after oral argument, four justices dissenting. See App. to Pet. for Cert. 1a-2a. This Court granted certiorari on March 9, 2020, after a similar case became moot. See Mathena v. Malvo, 140 S. Ct. 919, 206 L. Ed. 2d 250 (Feb. 26, 2020).

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Summary of Argument

Brett Jones, at the age of 15, left his home in Florida and resided with his grandfather, Bert Jones, in Mississippi. Two months later, Jones fatally stabbed his grandfather. The killing was characterized as "particularly brutal," with Jones inflicting eight stab wounds and attempting to conceal the act.

Jones claimed self-defense at trial, but the jury rejected this defense, finding him guilty of deliberate-design murder. Jones was sentenced to life imprisonment.

Post-Conviction Proceedings

Following the Supreme Court's decision in Miller v. Alabama (2012), which held that mandatory life sentences without parole for juveniles were unconstitutional, the Mississippi Supreme Court granted certiorari to consider the retroactivity of Miller. The court held that Miller was retroactive on collateral review and remanded Jones's case for resentencing.

Resentencing

During resentencing, the trial judge considered Jones's age and family situation. The judge explicitly stated that he had weighed the Miller factors and determined that Jones was not entitled to a reduced sentence that would make him eligible for parole.

Appellate Review

The Court of Appeals affirmed the trial court's decision. The Mississippi Supreme Court granted certiorari but dismissed the writ after oral argument, with four justices dissenting.

Conclusion

The case of Brett Jones highlights the complexities of sentencing juveniles who commit serious crimes. The trial court's resentencing decision, which was upheld on appeal, reflects a balancing of the mitigating factors of Jones's youth and family circumstances with the gravity of the offense he committed.

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Summary of Argument

Background

  • At 15, Brett Jones left his abusive home in Florida and moved in with his grandfather, Bert Jones, in Mississippi.

  • Two months later, Jones brutally stabbed his grandfather to death, using two knives and inflicting defensive wounds on his grandfather's hands.

Trial and Sentencing

  • Jones claimed self-defense, but the jury rejected his claim and found him guilty of murder.

  • He was sentenced to life imprisonment.

Miller v. Alabama and Resentencing

  • After the Supreme Court ruled in Miller v. Alabama that mandatory life sentences for juveniles were unconstitutional, Jones's case was reviewed.

  • The Mississippi Supreme Court ordered a resentencing hearing.

  • At the hearing, the judge considered Jones's age and family situation but declined to reduce his sentence.

Appeals and Certiorari

  • Jones appealed the resentencing decision, but it was upheld by the Court of Appeals.

  • The Mississippi Supreme Court initially granted certiorari (a request for review) but later dismissed it, with four justices dissenting.

  • The U.S. Supreme Court granted certiorari to review the case.

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Summary of Argument

The Case:

  • At age 15, Brett Jones left his home in Florida and moved in with his grandfather, Bert Jones, in Mississippi.

  • Two months later, Brett stabbed his grandfather to death.

  • The killing was very violent. Brett stabbed his grandfather eight times and tried to hide what he had done.

  • Brett claimed he acted in self-defense, but the jury did not believe him.

The Trial and Sentencing:

  • Brett was found guilty of murder and sentenced to life in prison.

  • Later, a higher court ruled that Brett's sentence should be reviewed because of his age at the time of the crime.

  • The trial judge reviewed the case and decided that Brett's sentence should not be changed.

  • The Mississippi Supreme Court reviewed the case but was unable to reach a decision.

Current Status:

  • The U.S. Supreme Court is now reviewing Brett's case.

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Summary of Argument

When Brett Jones was 15, he left his home in Florida because his stepfather was abusing him. He went to live with his grandfather, Bert Jones, in Mississippi. Two months later, Brett stabbed his grandfather eight times and killed him. Brett said he killed his grandfather because he was defending himself, but the jury didn't believe him. They found him guilty of murder and he was sentenced to life in prison.

After the trial, a new rule was made that said it was wrong to sentence young people to life in prison without the chance of parole. This meant that Brett's sentence could be changed.

The judge looked at all the facts of the case and decided that Brett should not get a shorter sentence. He said that Brett's crime was very serious and that he didn't deserve to be let out of prison early.

Brett appealed the judge's decision, but the higher court agreed with the judge. They said that Brett's sentence should stay the same.

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Footnotes and Citation

Cite

Brief Amicus Curiae of the Criminal Justice Legal Foundation in Support of Respondent, Jones v. Mississippi, No. 18-1259 (U.S. 2020).

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