Commonwealth v. Phillips
SummaryOriginal

Summary

Phillips appealed dismissal of PCRA petition seeking resentencing for juvenile murder conviction. PA Superior Court denied relief, citing PCRA filing deadline and that Miller v. Alabama didn't guarantee resentencing in all cases.

2015 | State Juristiction

Commonwealth v. Phillips

Keywords Miller v. Alabama; retroactive application of Miller; LWOP; juvenile life without parole; resentencing of juvenile offenders; Pennsylvania Post-Conviction Relief Act (PCRA)

Abstract

This case involved Aaron Claude Phillips appealing the dismissal of his petition for post-conviction relief under the Pennsylvania Post-Conviction Relief Act (PCRA). Phillips was convicted of second-degree murder and other offenses as a juvenile in 1988 and sentenced to life in prison without parole. In 2012, the U.S. Supreme Court case Miller v. Alabama established that mandatory life sentences for juveniles violated the Eighth Amendment's ban on cruel and unusual punishment. Phillips argued that Miller v. Alabama should be applied retroactively to his case, entitling him to relief. The Pennsylvania Superior Court disagreed. The court acknowledged Miller v. Alabama but found Phillips's petition was untimely filed under the PCRA. Additionally, the court determined Miller v. Alabama did not automatically require resentencing in all pre-existing juvenile life sentence cases.

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Abstract

This case involved Aaron Claude Phillips appealing the dismissal of his petition for post-conviction relief under the Pennsylvania Post-Conviction Relief Act (PCRA). Phillips was convicted of second-degree murder and other offenses as a juvenile in 1988 and sentenced to life in prison without parole. In 2012, the U.S. Supreme Court case Miller v. Alabama established that mandatory life sentences for juveniles violated the Eighth Amendment's ban on cruel and unusual punishment. Phillips argued that Miller v. Alabama should be applied retroactively to his case, entitling him to relief. The Pennsylvania Superior Court disagreed. The court acknowledged Miller v. Alabama but found Phillips's petition was untimely filed under the PCRA. Additionally, the court determined Miller v. Alabama did not automatically require resentencing in all pre-existing juvenile life sentence cases.

This case concerned an appeal by Aaron Claude Phillips against the dismissal of his petition for post-conviction relief pursuant to the Pennsylvania Post-Conviction Relief Act (PCRA). Mr. Phillips was convicted of second-degree murder and other criminal violations as a minor in 1988, resulting in a sentence of life imprisonment without the possibility of parole. Following the 2012 Supreme Court ruling in Miller v. Alabama, which held that mandatory life sentences without parole for juveniles constituted a violation of the Eighth Amendment's prohibition against cruel and unusual punishment, Mr. Phillips asserted that Miller should be applied retroactively to his case, thereby affording him grounds for relief.

The Pennsylvania Superior Court rejected this argument. While acknowledging the precedent set by Miller v. Alabama, the court determined that Mr. Phillips's petition was not filed within the timeframe stipulated by the PCRA. Furthermore, the court held that Miller v. Alabama did not inherently mandate resentencing in all cases predating the ruling where juveniles had been sentenced to life in prison.

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Abstract

This case involved Aaron Claude Phillips appealing the dismissal of his petition for post-conviction relief under the Pennsylvania Post-Conviction Relief Act (PCRA). Phillips was convicted of second-degree murder and other offenses as a juvenile in 1988 and sentenced to life in prison without parole. In 2012, the U.S. Supreme Court case Miller v. Alabama established that mandatory life sentences for juveniles violated the Eighth Amendment's ban on cruel and unusual punishment. Phillips argued that Miller v. Alabama should be applied retroactively to his case, entitling him to relief. The Pennsylvania Superior Court disagreed. The court acknowledged Miller v. Alabama but found Phillips's petition was untimely filed under the PCRA. Additionally, the court determined Miller v. Alabama did not automatically require resentencing in all pre-existing juvenile life sentence cases.

Aaron Claude Phillips, who was convicted of second-degree murder as a teenager in 1988 and given a life sentence without the possibility of parole, recently had his request for a new trial denied. Phillips based his appeal on a 2012 Supreme Court decision, Miller v. Alabama, which found that mandatory life sentences for minors were unconstitutional.

While the Pennsylvania Superior Court acknowledged the Miller v. Alabama ruling, they dismissed Phillips's appeal because it was submitted too late according to the state's Post-Conviction Relief Act (PCRA). The court further clarified that the Miller v. Alabama decision didn't automatically guarantee a resentencing for everyone previously sentenced to life in prison as juveniles.

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Abstract

This case involved Aaron Claude Phillips appealing the dismissal of his petition for post-conviction relief under the Pennsylvania Post-Conviction Relief Act (PCRA). Phillips was convicted of second-degree murder and other offenses as a juvenile in 1988 and sentenced to life in prison without parole. In 2012, the U.S. Supreme Court case Miller v. Alabama established that mandatory life sentences for juveniles violated the Eighth Amendment's ban on cruel and unusual punishment. Phillips argued that Miller v. Alabama should be applied retroactively to his case, entitling him to relief. The Pennsylvania Superior Court disagreed. The court acknowledged Miller v. Alabama but found Phillips's petition was untimely filed under the PCRA. Additionally, the court determined Miller v. Alabama did not automatically require resentencing in all pre-existing juvenile life sentence cases.

Aaron Claude Phillips, who was found guilty of murder and other crimes as a teenager back in 1988, wanted his life sentence without parole reconsidered. Phillips argued that a big Supreme Court case from 2012, Miller v. Alabama, should apply to his situation. In that case, the Court decided that forcing juveniles to serve life without parole was a cruel and unusual punishment, which is banned by the Eighth Amendment. Since Phillips was a juvenile when sentenced, he believed he deserved a new hearing.

However, the Pennsylvania Superior Court said no. While the court recognized the importance of Miller v. Alabama, they said Phillips's request was filed too late based on Pennsylvania's rules. They also clarified that Miller v. Alabama didn't mean everyone who received a life sentence as a juvenile automatically gets a new sentencing hearing.

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Abstract

This case involved Aaron Claude Phillips appealing the dismissal of his petition for post-conviction relief under the Pennsylvania Post-Conviction Relief Act (PCRA). Phillips was convicted of second-degree murder and other offenses as a juvenile in 1988 and sentenced to life in prison without parole. In 2012, the U.S. Supreme Court case Miller v. Alabama established that mandatory life sentences for juveniles violated the Eighth Amendment's ban on cruel and unusual punishment. Phillips argued that Miller v. Alabama should be applied retroactively to his case, entitling him to relief. The Pennsylvania Superior Court disagreed. The court acknowledged Miller v. Alabama but found Phillips's petition was untimely filed under the PCRA. Additionally, the court determined Miller v. Alabama did not automatically require resentencing in all pre-existing juvenile life sentence cases.

Aaron Claude Phillips was found guilty of murder and other crimes in 1988 when he was still a teenager. He was given a life sentence in prison. In 2012, the highest court in the U.S. decided in a case called Miller v. Alabama that giving minors a life sentence is unfair and against the Eighth Amendment.

Phillips thought this decision meant he should be able to challenge his sentence. However, the Pennsylvania Superior Court, another court, disagreed. While they considered Miller v. Alabama important, they decided Phillips waited too long to appeal. In addition, they also said the Miller v. Alabama decision didn't automatically mean everyone sentenced as a minor should receive a new sentence.

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Footnotes and Citation

Cite

Commonwealth v. Phillips, No. 3005 EDA 2014 (Pa. Super. Ct. Aug. 11, 2015)

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