Carter v. State
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Summary

Maryland Court of Appeals upheld life sentence for juvenile offender Carter. Parole system offers potential for release based on rehabilitation, meeting Eighth Amendment requirements.

2018 | State Juristiction

Carter v. State

Keywords juvenile life without parole; LWOP; Eighth Amendment (U.S.); cruel and unusual punishment; Maryland parole system; potential for rehabilitation; meaningful opportunity for release

Abstract

Daniel Carter v. State of Maryland (2018) addressed the constitutionality of life sentences for juvenile offenders in Maryland. Carter, sentenced to life for murder as a juvenile, argued his sentence violated the Eighth Amendment's prohibition on cruel and unusual punishment. The Court of Appeals of Maryland examined whether Maryland's parole system offered a "meaningful opportunity" for release based on rehabilitation, a requirement established by recent Supreme Court rulings. The Court concluded Maryland's parole system, on its face, provided such an opportunity. However, they did not comment on whether the system functioned as intended in practice.

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Abstract

Daniel Carter v. State of Maryland (2018) addressed the constitutionality of life sentences for juvenile offenders in Maryland. Carter, sentenced to life for murder as a juvenile, argued his sentence violated the Eighth Amendment's prohibition on cruel and unusual punishment. The Court of Appeals of Maryland examined whether Maryland's parole system offered a "meaningful opportunity" for release based on rehabilitation, a requirement established by recent Supreme Court rulings. The Court concluded Maryland's parole system, on its face, provided such an opportunity. However, they did not comment on whether the system functioned as intended in practice.

In the case of Daniel Carter v. State of Maryland (2018), the Court of Appeals of Maryland considered the constitutionality of life sentences imposed on individuals for crimes committed as minors. The Appellant, Daniel Carter, received a life sentence for murder committed as a juvenile. He argued that such a sentence constituted cruel and unusual punishment, thereby violating the Eighth Amendment to the United States Constitution. Central to the Court's analysis was whether Maryland's parole system, as structured, afforded juvenile offenders a "meaningful opportunity" for release contingent upon demonstrated rehabilitation, a requirement established by recent Supreme Court precedents. The Court ultimately held that the statutory framework of Maryland's parole system, prima facie, provided this opportunity. However, the Court refrained from commenting on the efficacy of the parole system's practical application.

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Abstract

Daniel Carter v. State of Maryland (2018) addressed the constitutionality of life sentences for juvenile offenders in Maryland. Carter, sentenced to life for murder as a juvenile, argued his sentence violated the Eighth Amendment's prohibition on cruel and unusual punishment. The Court of Appeals of Maryland examined whether Maryland's parole system offered a "meaningful opportunity" for release based on rehabilitation, a requirement established by recent Supreme Court rulings. The Court concluded Maryland's parole system, on its face, provided such an opportunity. However, they did not comment on whether the system functioned as intended in practice.

The case of Daniel Carter v. State of Maryland (2018) centered around the question of whether life sentences for individuals who committed crimes as juveniles were constitutional in Maryland. Carter, who received a life sentence for murder as a juvenile, argued that this punishment went against the Eighth Amendment's ban on cruel and unusual punishment. The Maryland Court of Appeals focused on whether the state's parole system offered a genuine chance for release based on rehabilitation, a requirement set by recent Supreme Court decisions. Ultimately, the Court determined that, in theory, Maryland's parole system did provide such an opportunity. However, they stopped short of addressing whether the system actually functioned as intended in practice.

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Abstract

Daniel Carter v. State of Maryland (2018) addressed the constitutionality of life sentences for juvenile offenders in Maryland. Carter, sentenced to life for murder as a juvenile, argued his sentence violated the Eighth Amendment's prohibition on cruel and unusual punishment. The Court of Appeals of Maryland examined whether Maryland's parole system offered a "meaningful opportunity" for release based on rehabilitation, a requirement established by recent Supreme Court rulings. The Court concluded Maryland's parole system, on its face, provided such an opportunity. However, they did not comment on whether the system functioned as intended in practice.

In 2018, a Maryland court heard a case about whether it was constitutional to give someone a life sentence for a crime they committed as a teenager. Daniel Carter, who received a life sentence for murder he committed as a minor, argued that this punishment was too harsh and went against the Eighth Amendment, which bans "cruel and unusual punishment." The big question for the Maryland Court of Appeals was whether the state's parole system gave people like Carter a real chance at release if they showed they had changed for the better. The Court decided that, at least on paper, Maryland's system did seem to give a fair shot at parole. However, they didn't say whether the system actually worked that way in real life.

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Abstract

Daniel Carter v. State of Maryland (2018) addressed the constitutionality of life sentences for juvenile offenders in Maryland. Carter, sentenced to life for murder as a juvenile, argued his sentence violated the Eighth Amendment's prohibition on cruel and unusual punishment. The Court of Appeals of Maryland examined whether Maryland's parole system offered a "meaningful opportunity" for release based on rehabilitation, a requirement established by recent Supreme Court rulings. The Court concluded Maryland's parole system, on its face, provided such an opportunity. However, they did not comment on whether the system functioned as intended in practice.

In 2018, a court case in Maryland called Daniel Carter v. State of Maryland looked at whether it was fair to give a teenager a life sentence in prison. Daniel Carter, who was sentenced to life in prison for murder when he was a teenager, argued that this punishment was too harsh and went against the Eighth Amendment. The Eighth Amendment says that people can't be given cruel and unusual punishments.

The highest court in Maryland looked at whether the state's parole system (a way for prisoners to be released early for good behavior) gave people like Carter a real chance to get out of prison if they showed they had changed for the better. The court decided that, based on how the parole system was written, it seemed to give people a real chance to be released. However, the court didn't say whether they thought the parole system actually worked the way it was supposed to in real life.

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Footnotes and Citation

Cite

Carter v. State, 461 Md. 295 (Md. 2018)

Highlights