Commonwealth v. King
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Summary

PA Supreme Court allows resentencing for Ivory King's juvenile crimes. Miller v. Alabama applied retroactively, ensuring consideration of King's youth and rehabilitation potential in sentencing.

2016 | State Juristiction

Commonwealth v. King

Keywords de facto life sentence; LWOP; juvenile life without parole; resentencing hearing ; potential for rehabilitation of juveniles; Pennsylvania Post-Conviction Relief Act; Miller v. Alabama; retroactive application of Miller

Abstract

The case of Commonwealth of Pennsylvania v. Ivory King (filed in the Superior Court of Pennsylvania, No. 3323 EDA 2014) involved King appealing a PCRA (Post Conviction Relief Act) order issued in November of 2014 by the Court of Common Pleas of Bucks County.

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Abstract

The case of Commonwealth of Pennsylvania v. Ivory King (filed in the Superior Court of Pennsylvania, No. 3323 EDA 2014) involved King appealing a PCRA (Post Conviction Relief Act) order issued in November of 2014 by the Court of Common Pleas of Bucks County.

In the case of Commonwealth v. King, the Pennsylvania Supreme Court addressed the issue of whether the U.S. Supreme Court's decision in Miller v. Alabama (2012), which barred mandatory life sentences without the possibility of parole (LWOP) for juvenile offenders, applied retroactively. Ivory King, who received a mandatory LWOP sentence for crimes committed at age 15, sought resentencing under the Pennsylvania Post-Conviction Relief Act (PCRA) following the Miller decision. The court found in favor of King, holding that the principles articulated in Miller, particularly regarding evolving societal standards and the rehabilitative capacity of juveniles, justified the retroactive application of the ruling. Consequently, the court determined that King was entitled to a new sentencing hearing, one that considered his youth at the time of the offense and his potential for rehabilitation, thereby allowing for the possibility of parole.

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Abstract

The case of Commonwealth of Pennsylvania v. Ivory King (filed in the Superior Court of Pennsylvania, No. 3323 EDA 2014) involved King appealing a PCRA (Post Conviction Relief Act) order issued in November of 2014 by the Court of Common Pleas of Bucks County.

Ivory King, who was found guilty of several crimes including attempted murder as a teenager (at age 15), was given a mandatory sentence of life in prison without the possibility of parole (LWOP) in Pennsylvania. After the Supreme Court's decision in Miller v. Alabama (2012), which found mandatory LWOP sentences for juvenile offenders unconstitutional, King filed a request for a new sentence under the Pennsylvania Post-Conviction Relief Act (PCRA).

The main question in this case was whether Miller v. Alabama could be applied retroactively to King's case. The Pennsylvania Supreme Court ruled in favor of King. They decided that the reasoning behind Miller v. Alabama, which focused on changing societal views and the potential for rehabilitation in young people, meant the decision should apply retroactively. This ruling means King is entitled to a new sentencing hearing where his age at the time of the crime and his potential for rehabilitation will be considered, potentially allowing for his eventual release from prison.

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Abstract

The case of Commonwealth of Pennsylvania v. Ivory King (filed in the Superior Court of Pennsylvania, No. 3323 EDA 2014) involved King appealing a PCRA (Post Conviction Relief Act) order issued in November of 2014 by the Court of Common Pleas of Bucks County.

Ivory King was found guilty of several crimes, including trying to kill someone, when he was only 15 years old. Because of the laws at the time, the judge had no choice but to sentence him to life in prison without the chance of ever getting out. However, a few years later, the highest court in the United States (the Supreme Court) decided in a different case (Miller v. Alabama) that it is unconstitutional to automatically give kids a life sentence without considering their age and if they could change for the better. This meant that kids who commit crimes should have a chance to argue for a different sentence, like one that includes the possibility of parole (getting out of prison early for good behavior).

Because of that Supreme Court decision, King asked the Pennsylvania court to reconsider his sentence. He argued that the Miller v. Alabama decision should apply to his case too, even though it happened before that ruling. The Pennsylvania Supreme Court agreed with King. They said that the ideas behind Miller v. Alabama - the fact that our understanding of what's fair changes over time, and that young people are more likely to be able to turn their lives around - meant that King deserved a new sentencing hearing. This time, the judge would have to consider how old King was when he committed the crime and whether he might be able to rehabilitate. The court's decision means that King might have a chance to get out of prison someday.

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Abstract

The case of Commonwealth of Pennsylvania v. Ivory King (filed in the Superior Court of Pennsylvania, No. 3323 EDA 2014) involved King appealing a PCRA (Post Conviction Relief Act) order issued in November of 2014 by the Court of Common Pleas of Bucks County.

When Ivory King was 15 years old, he was convicted of some very serious crimes, including trying to kill someone. In Pennsylvania, the law said that the judge had to give him a life sentence in prison, which meant he could never be let out.

However, a few years later the Supreme Court decided in the case of Miller v. Alabama that giving automatic life sentences to kids was wrong. They said that judges should have to think about how young someone was and how they might change for the better as they got older.

Because of this new Supreme Court decision, Ivory King asked the Pennsylvania courts to give him a new sentence. The biggest question was whether the Miller v. Alabama decision applied to King even though his sentence happened before that decision.

The highest court in Pennsylvania agreed with Ivory King. They said that the reasons behind the Miller v. Alabama decision, like the idea that kids can change and deserve a second chance, meant that it should apply to King's case too. This means that Ivory King got another day in court where the judge considered his age when he committed the crimes and the possibility that he might be able to leave prison someday.

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Footnotes and Citation

Cite

Commonwealth v. King, No. 3323 EDA 2014 (Pa. Super. Ct. filed Mar. 23, 2016)

Highlights