Commonwealth v. Bourgeois
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Summary

Bourgeois challenged life sentences for juvenile crimes, arguing court ignored factors for youth sentencing. Court disagreed, saying original sentencing considered these factors, and his lengthy sentences weren't a de- facto life term.

2019 | State Juristiction

Commonwealth v. Bourgeois

Keywords LWOP; de facto life imprisonment; juvenile life without parole; juvenile sentencing; Miller factors; potential for rehabilitation

Abstract

Michael Lee Bourgeois appealed his sentence of consecutive 40-to-life sentences for crimes he committed as a juvenile. He argued that the Pennsylvania trial court violated his Eighth Amendment rights by not considering the "Miller factors" at his resentencing hearing. These factors, established by the U.S. Supreme Court, require courts to weigh a juvenile's age and potential for rehabilitation when imposing punishment. The Superior Court of Pennsylvania disagreed. They ruled that the trial court did not need to hold a separate hearing on the Miller factors because they were already considered in the original sentencing. The court also determined that Bourgeois's consecutive sentences, though lengthy, did not constitute a de facto life sentence without parole.

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Abstract

Michael Lee Bourgeois appealed his sentence of consecutive 40-to-life sentences for crimes he committed as a juvenile. He argued that the Pennsylvania trial court violated his Eighth Amendment rights by not considering the "Miller factors" at his resentencing hearing. These factors, established by the U.S. Supreme Court, require courts to weigh a juvenile's age and potential for rehabilitation when imposing punishment. The Superior Court of Pennsylvania disagreed. They ruled that the trial court did not need to hold a separate hearing on the Miller factors because they were already considered in the original sentencing. The court also determined that Bourgeois's consecutive sentences, though lengthy, did not constitute a de facto life sentence without parole.

In the case of Commonwealth v. Bourgeois, Michael Lee Bourgeois appealed consecutive 40-to-life sentences imposed for crimes he committed as a juvenile. Bourgeois argued that the sentencing court violated the Eighth Amendment's prohibition against cruel and unusual punishment by neglecting to explicitly address the "Miller factors" during his resentencing hearing. These factors, articulated in Miller v. Alabama, mandate that courts consider a juvenile offender's age and capacity for rehabilitation when determining appropriate punishment.

The Pennsylvania Superior Court affirmed the trial court's decision, holding that a separate hearing to address the Miller factors was unnecessary. The court reasoned that the trial court's initial sentencing encompassed consideration of these factors. Furthermore, the court rejected Bourgeois's claim that the cumulative effect of his consecutive sentences constituted a de facto life sentence without parole, deeming the sentences constitutional.

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Abstract

Michael Lee Bourgeois appealed his sentence of consecutive 40-to-life sentences for crimes he committed as a juvenile. He argued that the Pennsylvania trial court violated his Eighth Amendment rights by not considering the "Miller factors" at his resentencing hearing. These factors, established by the U.S. Supreme Court, require courts to weigh a juvenile's age and potential for rehabilitation when imposing punishment. The Superior Court of Pennsylvania disagreed. They ruled that the trial court did not need to hold a separate hearing on the Miller factors because they were already considered in the original sentencing. The court also determined that Bourgeois's consecutive sentences, though lengthy, did not constitute a de facto life sentence without parole.

Michael Lee Bourgeois contested his consecutive 40-to-life sentences for crimes he committed while still a minor. Bourgeois argued that during his resentencing, the Pennsylvania trial court failed to consider the "Miller factors" as mandated by the U.S. Supreme Court. These factors require courts to take a juvenile offender's age and capacity for rehabilitation into account during sentencing.

However, the Pennsylvania Superior Court rejected Bourgeois's appeal. The court maintained that a separate hearing regarding the Miller factors was unnecessary since these factors had already been addressed in the initial sentencing. Additionally, the court ruled that Bourgeois's consecutive sentences, while substantial, did not equate to a life sentence without the possibility of parole and therefore did not violate his Eighth Amendment rights.

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Abstract

Michael Lee Bourgeois appealed his sentence of consecutive 40-to-life sentences for crimes he committed as a juvenile. He argued that the Pennsylvania trial court violated his Eighth Amendment rights by not considering the "Miller factors" at his resentencing hearing. These factors, established by the U.S. Supreme Court, require courts to weigh a juvenile's age and potential for rehabilitation when imposing punishment. The Superior Court of Pennsylvania disagreed. They ruled that the trial court did not need to hold a separate hearing on the Miller factors because they were already considered in the original sentencing. The court also determined that Bourgeois's consecutive sentences, though lengthy, did not constitute a de facto life sentence without parole.

Michael Lee Bourgeois, who committed crimes as a teenager, wanted his punishment reduced. He was serving back-to-back sentences of 40 years to life, which he claimed were unconstitutional. He argued that during his resentencing, the court didn't fully consider something called the "Miller factors," rules set by the highest court in the US that say judges have to think about a young person's age and chances of changing their life for the better when deciding on a punishment.

However, the Pennsylvania Superior Court - a higher court in the state - disagreed with Bourgeois. They said the original judge already thought about these factors during the first sentencing, so a whole new hearing wasn't necessary. The court also said that even though his sentences are long, they don't mean he'll automatically stay in prison forever without the possibility of parole.

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Abstract

Michael Lee Bourgeois appealed his sentence of consecutive 40-to-life sentences for crimes he committed as a juvenile. He argued that the Pennsylvania trial court violated his Eighth Amendment rights by not considering the "Miller factors" at his resentencing hearing. These factors, established by the U.S. Supreme Court, require courts to weigh a juvenile's age and potential for rehabilitation when imposing punishment. The Superior Court of Pennsylvania disagreed. They ruled that the trial court did not need to hold a separate hearing on the Miller factors because they were already considered in the original sentencing. The court also determined that Bourgeois's consecutive sentences, though lengthy, did not constitute a de facto life sentence without parole.

Michael Lee Bourgeois, a teenager who was given a very long prison sentence, recently went back to court. He said his punishment was unfair because the court didn't fully think about his age and chances of changing his life when they first sentenced him.

The higher court in Pennsylvania disagreed. They said the original court didn't need to have a whole new hearing about these things because they already thought about them the first time. Even though Bourgeois's sentence is very long, the court said it doesn't mean he will automatically stay in prison forever.

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Footnotes and Citation

Cite

Commonwealth v. Bourgeois, WL 1579816 (Pa. 2019)

Highlights