Baines v. Pennsylvania
SummaryOriginal

Summary

Franklin Baines (3rd Cir. 2013) asked the court to allow a second habeus corpus petition to challenge a juvenile life sentence under Miller v. Alabama. The court agreed to allow the condition provided certain conditions were met.

2013 | Federal Juristiction

Baines v. Pennsylvania

Keywords LWOP; juvenile life without parole; Pennsylvania Superior Court ; post-conviction relief; suppression of evidence; search and seizure; Fourth Amendment (U.S.); Eighth Amendment (U.S.)

Abstract

This case involved Franklin Baines' petition to file a second habeas corpus petition challenging his life sentence for a crime he committed as a juvenile. The Supreme Court had recently ruled in Miller v. Alabama that mandatory life sentences for juvenile offenders were unconstitutional. Baines argued that this new ruling entitled him to relief in his case. The Third Circuit Court of Appeals addressed whether Baines could raise this claim in a successive habeas petition. The court held that Baines could seek permission to file a successive habeas petition under specific conditions. Baines had to show that the new rule in Miller v. Alabama could not have been raised in his previous petition and that the rule applied to his case.

Open Case as PDF

Abstract

This case involved Franklin Baines' petition to file a second habeas corpus petition challenging his life sentence for a crime he committed as a juvenile. The Supreme Court had recently ruled in Miller v. Alabama that mandatory life sentences for juvenile offenders were unconstitutional. Baines argued that this new ruling entitled him to relief in his case. The Third Circuit Court of Appeals addressed whether Baines could raise this claim in a successive habeas petition. The court held that Baines could seek permission to file a successive habeas petition under specific conditions. Baines had to show that the new rule in Miller v. Alabama could not have been raised in his previous petition and that the rule applied to his case.

This case concerns Franklin Baines' petition for permission to file a second (successive) habeas corpus petition challenging his life sentence for a crime he committed as a minor. This petition arose from the Supreme Court's decision in Miller v. Alabama, which declared mandatory life sentences without the possibility of parole for juvenile offenders to be unconstitutional. Baines argued that the Miller decision constituted a significant legal change that applied retroactively to his case, thereby entitling him to relief. The Third Circuit Court of Appeals, in adjudicating this matter, addressed the legal standard for allowing successive habeas petitions.

The Court held that Baines could seek permission to file a successive habeas petition, but only if he satisfied specific conditions. Firstly, Baines needed to demonstrate that the legal argument based on Miller v. Alabama was not previously available, or reasonably could not have been raised, during his initial habeas petition. Secondly, Baines had to establish that the rule announced in Miller was applicable to the specific facts and circumstances of his case.

Open Case as PDF

Abstract

This case involved Franklin Baines' petition to file a second habeas corpus petition challenging his life sentence for a crime he committed as a juvenile. The Supreme Court had recently ruled in Miller v. Alabama that mandatory life sentences for juvenile offenders were unconstitutional. Baines argued that this new ruling entitled him to relief in his case. The Third Circuit Court of Appeals addressed whether Baines could raise this claim in a successive habeas petition. The court held that Baines could seek permission to file a successive habeas petition under specific conditions. Baines had to show that the new rule in Miller v. Alabama could not have been raised in his previous petition and that the rule applied to his case.

This case focused on Franklin Baines' request to file a second habeas corpus petition. Baines was serving a life sentence for a crime he committed as a minor, and he argued a recent Supreme Court decision, Miller v. Alabama, applied to his situation. In Miller, the Court found that mandatory life sentences for minors were unconstitutional.

The Third Circuit Court of Appeals had to determine if Baines was permitted to submit another petition based on this new legal precedent. Ultimately, the court decided that Baines could request permission to file a successive habeas corpus petition, but only if specific criteria were met. Baines needed to demonstrate that he couldn't have used the Miller ruling in his original petition and that the Miller decision was relevant to his specific case.

Open Case as PDF

Abstract

This case involved Franklin Baines' petition to file a second habeas corpus petition challenging his life sentence for a crime he committed as a juvenile. The Supreme Court had recently ruled in Miller v. Alabama that mandatory life sentences for juvenile offenders were unconstitutional. Baines argued that this new ruling entitled him to relief in his case. The Third Circuit Court of Appeals addressed whether Baines could raise this claim in a successive habeas petition. The court held that Baines could seek permission to file a successive habeas petition under specific conditions. Baines had to show that the new rule in Miller v. Alabama could not have been raised in his previous petition and that the rule applied to his case.

Franklin Baines, who was serving a life sentence for a crime he committed as a teenager, wanted to try to challenge his sentence again. He said a recent Supreme Court case, Miller v. Alabama, gave him a new argument. In Miller, the Court said it's unconstitutional to automatically give life sentences to minors. The Third Circuit Court of Appeals decided about whether Baines could bring this new argument in a second appeal about his case.

The court decided that Baines could file another appeal, but only if certain things were true. Baines has to prove that he couldn't have used the Miller case argument in his first appeal, and that the Miller ruling actually applied to his own situation.

Open Case as PDF

Abstract

This case involved Franklin Baines' petition to file a second habeas corpus petition challenging his life sentence for a crime he committed as a juvenile. The Supreme Court had recently ruled in Miller v. Alabama that mandatory life sentences for juvenile offenders were unconstitutional. Baines argued that this new ruling entitled him to relief in his case. The Third Circuit Court of Appeals addressed whether Baines could raise this claim in a successive habeas petition. The court held that Baines could seek permission to file a successive habeas petition under specific conditions. Baines had to show that the new rule in Miller v. Alabama could not have been raised in his previous petition and that the rule applied to his case.

Franklin Baines was a teenager when he did something wrong and was given a very serious punishment – he had to stay in prison for the rest of his life. Many years later, the highest court in the land, the Supreme Court, decided that giving automatic life sentences to kids was wrong. This new rule was made in a case called Miller v. Alabama. Franklin thought this new rule might help him, so he asked the court to look at his case again.

A special court, called the Third Circuit Court of Appeals, had to decide if Franklin could even ask to have his case looked at again since he already tried once before. They said Franklin could ask, but only if he could prove two things: First, he had to show that he couldn't have used the Miller v. Alabama rule in his first try. Second, he had to show that this new rule actually applied to his situation.

Open Case as PDF

Footnotes and Citation

Cite

In re Baines, 720 F.3d 285 (3d Cir. 2013)

Highlights