Armstrong v. People
SummaryOriginal

Summary

The Colorado Supreme Court upholds a 96-year sentence for a 16-year-old accomplice to murder. Her sentence was not deemed cruel and unusual punishment because it allowed eventual parole, unlike mandatory life sentences for juveniles.

2017 | State Juristiction

Armstrong v. People

Keywords juvenile offender; parole eligibility; Eighth Amendment (U.S.); cruel and unusual punishment; meaningful opportunity for release; Colorado Supreme Court; second-degree murder

Abstract

Cheryl Armstrong, convicted as a 16-year-old for second-degree murder under a complicity theory, challenged her lengthy sentence on appeal. She argued that due to her young age, the 96-year sentence – effectively a life sentence without parole – violated the Eighth Amendment's protection against cruel and unusual punishment. The Colorado Supreme Court disagreed, finding that unlike cases involving mandatory life without parole for juveniles, Armstrong's sentence, though long, allowed for parole eligibility, thus providing a "meaningful opportunity for release."

Open Case as PDF

Abstract

Cheryl Armstrong, convicted as a 16-year-old for second-degree murder under a complicity theory, challenged her lengthy sentence on appeal. She argued that due to her young age, the 96-year sentence – effectively a life sentence without parole – violated the Eighth Amendment's protection against cruel and unusual punishment. The Colorado Supreme Court disagreed, finding that unlike cases involving mandatory life without parole for juveniles, Armstrong's sentence, though long, allowed for parole eligibility, thus providing a "meaningful opportunity for release."

Cheryl Armstrong, who was convicted of second-degree murder under a complicity theory at age 16, appealed her 96-year sentence. Armstrong asserted that the sentence, effectively constituting life imprisonment without the possibility of parole, infringed upon the Eighth Amendment's prohibition against cruel and unusual punishment given her young age at the time of the offense. The Colorado Supreme Court rejected this argument, differentiating Armstrong's case from those involving mandatory life sentences without parole for juveniles. The court held that while lengthy, Armstrong's sentence did not preclude the possibility of parole, thereby affording her a "meaningful opportunity for release."

Open Case as PDF

Abstract

Cheryl Armstrong, convicted as a 16-year-old for second-degree murder under a complicity theory, challenged her lengthy sentence on appeal. She argued that due to her young age, the 96-year sentence – effectively a life sentence without parole – violated the Eighth Amendment's protection against cruel and unusual punishment. The Colorado Supreme Court disagreed, finding that unlike cases involving mandatory life without parole for juveniles, Armstrong's sentence, though long, allowed for parole eligibility, thus providing a "meaningful opportunity for release."

Cheryl Armstrong, who was convicted of second-degree murder at the age of 16 under a complicity theory, appealed her substantial 96-year sentence. Armstrong asserted that the sentence, effectively constituting life without parole due to her young age, infringed upon the Eighth Amendment's prohibition of cruel and unusual punishment. However, the Colorado Supreme Court rejected this argument, differentiating Armstrong's case from those involving mandatory life sentences without parole for juveniles. The Court maintained that Armstrong's sentence, while lengthy, still offered the possibility of parole, thereby affording her a "meaningful opportunity for release."

Open Case as PDF

Abstract

Cheryl Armstrong, convicted as a 16-year-old for second-degree murder under a complicity theory, challenged her lengthy sentence on appeal. She argued that due to her young age, the 96-year sentence – effectively a life sentence without parole – violated the Eighth Amendment's protection against cruel and unusual punishment. The Colorado Supreme Court disagreed, finding that unlike cases involving mandatory life without parole for juveniles, Armstrong's sentence, though long, allowed for parole eligibility, thus providing a "meaningful opportunity for release."

Cheryl Armstrong, who was found guilty of helping someone commit second-degree murder when she was only 16 years old, asked a court to reconsider her 96-year prison sentence. She argued that such a long sentence, basically a life sentence without the chance of ever getting out, was unfair and cruel punishment for someone her age. The Colorado Supreme Court, however, disagreed. They pointed out that, unlike other cases where kids were automatically given life without parole, Armstrong's sentence, while long, does give her a chance to be released on parole at some point. This means she still has a real possibility of freedom in the future.

Open Case as PDF

Abstract

Cheryl Armstrong, convicted as a 16-year-old for second-degree murder under a complicity theory, challenged her lengthy sentence on appeal. She argued that due to her young age, the 96-year sentence – effectively a life sentence without parole – violated the Eighth Amendment's protection against cruel and unusual punishment. The Colorado Supreme Court disagreed, finding that unlike cases involving mandatory life without parole for juveniles, Armstrong's sentence, though long, allowed for parole eligibility, thus providing a "meaningful opportunity for release."

Cheryl Armstrong was a teenager, just 16 years old, when she was convicted of helping someone commit a very serious crime called second-degree murder. Because of her involvement, she was given a very long sentence of 96 years in prison. Armstrong argued that this punishment was too harsh, especially since she would be an old woman before she could even ask to be let out of prison. She said such a long sentence was like a life sentence, which was a "cruel" punishment and went against the Eight Amendment of the Constitution.

The highest court in Colorado, however, decided to keep Armstrong's sentence the same. The court said that even though her sentence was long, Armstrong would still have a chance to ask for parole, meaning she could one day ask to be let out of prison, and it did not violate the Eight Amendment.

Open Case as PDF

Footnotes and Citation

Cite

Armstrong v. People, 395 P.3d 748 (Colo. 2017).

Highlights