Commonwealth v. Lee
SummaryOriginal

Summary

Avis Lee, sentenced to life without parole at 18, appealed based on Miller v. Alabama's ban on juvenile LWOP sentences. Pennsylvania Superior Court denied appeal, citing precedent despite recognizing brain development research.

2019 | State Juristiction

Commonwealth v. Lee

Keywords Pennsylvania Superior Court; attempted robbery; LWOP; shooting death; characteristics of youth

Abstract

The case of Commonwealth of Pennsylvania v. Avis Lee (2017) involved a challenge to a mandatory life without parole sentence for a crime committed when Lee was 18 years old. Lee argued that the U.S. Supreme Court's decision in Miller v. Alabama (2012), prohibiting LWOP sentences for juveniles, should be applied retroactively to her case. The Pennsylvania Superior Court affirmed the dismissal of Lee's petition. The court acknowledged the evolving science on brain development in young adults but felt bound by precedent to reject Lee's claim. This case highlights the ongoing debate about applying evolving legal standards to past convictions.

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Abstract

The case of Commonwealth of Pennsylvania v. Avis Lee (2017) involved a challenge to a mandatory life without parole sentence for a crime committed when Lee was 18 years old. Lee argued that the U.S. Supreme Court's decision in Miller v. Alabama (2012), prohibiting LWOP sentences for juveniles, should be applied retroactively to her case. The Pennsylvania Superior Court affirmed the dismissal of Lee's petition. The court acknowledged the evolving science on brain development in young adults but felt bound by precedent to reject Lee's claim. This case highlights the ongoing debate about applying evolving legal standards to past convictions.

The Pennsylvania Superior Court case of Commonwealth of Pennsylvania v. Avis Lee (2017) centered on the application of the U.S. Supreme Court's holding in Miller v. Alabama (2012). Lee, who received a mandatory life sentence without the possibility of parole (LWOP) for a crime committed at age 18, argued that Miller, which prohibited mandatory LWOP sentences for individuals under 18 at the time of their offenses, should apply retroactively to her case. Despite acknowledging the developing scientific understanding of brain development in young adults, the Superior Court upheld the dismissal of Lee's petition, citing binding precedent. Lee exemplifies the ongoing legal discourse regarding the retroactive application of evolving legal precedents to past convictions.

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Abstract

The case of Commonwealth of Pennsylvania v. Avis Lee (2017) involved a challenge to a mandatory life without parole sentence for a crime committed when Lee was 18 years old. Lee argued that the U.S. Supreme Court's decision in Miller v. Alabama (2012), prohibiting LWOP sentences for juveniles, should be applied retroactively to her case. The Pennsylvania Superior Court affirmed the dismissal of Lee's petition. The court acknowledged the evolving science on brain development in young adults but felt bound by precedent to reject Lee's claim. This case highlights the ongoing debate about applying evolving legal standards to past convictions.

The case of Commonwealth of Pennsylvania v. Avis Lee (2017) centered around Avis Lee's challenge to her sentence of life in prison without parole (LWOP) for a crime she committed at 18. Lee argued that the landmark Supreme Court ruling in Miller v. Alabama (2012), which deemed mandatory LWOP sentences for minors unconstitutional, should be applied retroactively to her case.

The Pennsylvania Superior Court ultimately upheld the lower court's dismissal of Lee's petition. While acknowledging the growing body of scientific research on brain development in young adults, the court maintained that existing legal precedent prevented them from granting Lee's request. This case exemplifies the ongoing legal and ethical discussions surrounding the application of evolving legal standards to individuals convicted under previous interpretations of the law.

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Abstract

The case of Commonwealth of Pennsylvania v. Avis Lee (2017) involved a challenge to a mandatory life without parole sentence for a crime committed when Lee was 18 years old. Lee argued that the U.S. Supreme Court's decision in Miller v. Alabama (2012), prohibiting LWOP sentences for juveniles, should be applied retroactively to her case. The Pennsylvania Superior Court affirmed the dismissal of Lee's petition. The court acknowledged the evolving science on brain development in young adults but felt bound by precedent to reject Lee's claim. This case highlights the ongoing debate about applying evolving legal standards to past convictions.

In 2017, Avis Lee appealed her life sentence without parole (LWOP) in a Pennsylvania court. Lee, who committed the crime at 18, argued that her sentence should be reconsidered based on a 2012 Supreme Court ruling, Miller v. Alabama. This ruling stated that mandatory LWOP sentences for crimes committed by minors were unconstitutional.

The Pennsylvania Superior Court ultimately disagreed with Lee and upheld the original sentence. While acknowledging scientific research highlighting the ongoing brain development of young adults, the court explained its decision was bound by previous legal rulings. This case demonstrates the complexities of applying new legal interpretations to older cases.

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Abstract

The case of Commonwealth of Pennsylvania v. Avis Lee (2017) involved a challenge to a mandatory life without parole sentence for a crime committed when Lee was 18 years old. Lee argued that the U.S. Supreme Court's decision in Miller v. Alabama (2012), prohibiting LWOP sentences for juveniles, should be applied retroactively to her case. The Pennsylvania Superior Court affirmed the dismissal of Lee's petition. The court acknowledged the evolving science on brain development in young adults but felt bound by precedent to reject Lee's claim. This case highlights the ongoing debate about applying evolving legal standards to past convictions.

In 2017, Avis Lee asked a Pennsylvania court to change her sentence. Lee was 18 years old when she committed a crime that resulted in a life sentence with no chance of ever getting out of prison. She argued that her punishment was unfair because, in 2012, the U.S. Supreme Court decided that sentencing people under 18 years old to life in prison without the possibility of parole was unconstitutional.

The Pennsylvania court decided not to change Lee's sentence. The court recognized that scientists are learning more about how young people's brains develop, but it felt that its decision had to follow older court cases. This case shows how people disagree about whether new legal rules should apply to people who were convicted of crimes before those rules existed.

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Footnotes and Citation

Cite

Commonwealth v. Lee, 206 A.3d 1 (Pa. Super. Ct. 2019)

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