Commonwealth v. Seskey
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2017 | State Juristiction

Commonwealth v. Seskey

Keywords juvenile offender; Commonwealth v. Batts; life without parole; LWOP; juvenile life without parole; JLWOP; Montgomery v. Louisiana; Miller v. Alabama; resentencing

Abstract

In this case, a defendant, Mr. Seskey, was convicted of first-degree murder and sentenced to life without parole for crimes he committed as a juvenile. He appealed several times to correct the sentence, but all appeals were denied. In light of the 2016 U.S. Supreme Court's decision in Montgomery v. Louisiana, where the Court held that the rule against mandatory sentences of life without parole for juvenile offenders could be applied retroactively, Mr. Seskey appealed once again. The State argued that he must receive a maximum term of life in prison, but the trial court resentenced him to 13 to 26 years' imprisonment. On appeal, the trial court agreed that Mr. Seskey should immediately be released on parole. The Superior Court of Pennsylvania addressed the question of whether the rules established by the Pennsylvania Supreme Court in Commonwealth v. Batts applied to this case. In Commonwealth v. Batts, the Court held that juvenile defendants convicted of murder prior to June 25, 2012 are subject to a mandatory maximum sentence of life in prison when a sentencing court has determined that a sentence of life without parole is inappropriate when considering the factors established by the U.S. Supreme Court in Miller v. Alabama. Based on this, the Superior Court ruled that the lower court had failed to follow this rule in sentencing Mr. Seskey to 13 to 26 years in prison, so the case was remanded for resentencing.

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Abstract

In this case, a defendant, Mr. Seskey, was convicted of first-degree murder and sentenced to life without parole for crimes he committed as a juvenile. He appealed several times to correct the sentence, but all appeals were denied. In light of the 2016 U.S. Supreme Court's decision in Montgomery v. Louisiana, where the Court held that the rule against mandatory sentences of life without parole for juvenile offenders could be applied retroactively, Mr. Seskey appealed once again. The State argued that he must receive a maximum term of life in prison, but the trial court resentenced him to 13 to 26 years' imprisonment. On appeal, the trial court agreed that Mr. Seskey should immediately be released on parole. The Superior Court of Pennsylvania addressed the question of whether the rules established by the Pennsylvania Supreme Court in Commonwealth v. Batts applied to this case. In Commonwealth v. Batts, the Court held that juvenile defendants convicted of murder prior to June 25, 2012 are subject to a mandatory maximum sentence of life in prison when a sentencing court has determined that a sentence of life without parole is inappropriate when considering the factors established by the U.S. Supreme Court in Miller v. Alabama. Based on this, the Superior Court ruled that the lower court had failed to follow this rule in sentencing Mr. Seskey to 13 to 26 years in prison, so the case was remanded for resentencing.

Summary

Mr. Seskey, a defendant convicted of first-degree murder as a juvenile, was sentenced to life imprisonment without parole. He appealed this sentence multiple times, with all appeals being denied. Following the Supreme Court's decision in Montgomery v. Louisiana, which made the rule against mandatory life without parole sentences for juveniles retroactively applicable, Mr. Seskey filed another appeal. The State argued for a maximum life sentence, however, the trial court ultimately resentenced him to 13 to 26 years' imprisonment. Subsequently, the trial court granted him immediate parole.

The Superior Court of Pennsylvania reviewed the case, focusing on whether the rules established in Commonwealth v. Batts applied. In Commonwealth v. Batts, the Pennsylvania Supreme Court ruled that juvenile murder defendants convicted before June 25, 2012, were subject to a mandatory maximum sentence of life imprisonment if a sentencing court deemed a life without parole sentence inappropriate. The Superior Court concluded that the lower court had erred in sentencing Mr. Seskey to 13 to 26 years, as it had not adhered to the rule in Commonwealth v. Batts, and remanded the case for resentencing.

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Abstract

In this case, a defendant, Mr. Seskey, was convicted of first-degree murder and sentenced to life without parole for crimes he committed as a juvenile. He appealed several times to correct the sentence, but all appeals were denied. In light of the 2016 U.S. Supreme Court's decision in Montgomery v. Louisiana, where the Court held that the rule against mandatory sentences of life without parole for juvenile offenders could be applied retroactively, Mr. Seskey appealed once again. The State argued that he must receive a maximum term of life in prison, but the trial court resentenced him to 13 to 26 years' imprisonment. On appeal, the trial court agreed that Mr. Seskey should immediately be released on parole. The Superior Court of Pennsylvania addressed the question of whether the rules established by the Pennsylvania Supreme Court in Commonwealth v. Batts applied to this case. In Commonwealth v. Batts, the Court held that juvenile defendants convicted of murder prior to June 25, 2012 are subject to a mandatory maximum sentence of life in prison when a sentencing court has determined that a sentence of life without parole is inappropriate when considering the factors established by the U.S. Supreme Court in Miller v. Alabama. Based on this, the Superior Court ruled that the lower court had failed to follow this rule in sentencing Mr. Seskey to 13 to 26 years in prison, so the case was remanded for resentencing.

Summary

A defendant, Mr. Seskey, was convicted of first-degree murder and sentenced to life without parole for crimes committed as a juvenile. After multiple unsuccessful appeals, Mr. Seskey appealed again in light of the 2016 Supreme Court decision in Montgomery v. Louisiana, which permitted retroactive application of the rule against mandatory life without parole sentences for juveniles. The State argued for a life sentence, but the trial court resentenced Mr. Seskey to 13 to 26 years' imprisonment. The trial court then granted Mr. Seskey parole.

The Superior Court of Pennsylvania reviewed the case, addressing the applicability of rules established in Commonwealth v. Batts. Commonwealth v. Batts held that juvenile defendants convicted of murder before June 25, 2012, are subject to a mandatory maximum sentence of life imprisonment when a sentencing court deems life without parole inappropriate. Because the lower court did not follow this rule in sentencing Mr. Seskey to a term of years, the Superior Court remanded the case for resentencing.

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Abstract

In this case, a defendant, Mr. Seskey, was convicted of first-degree murder and sentenced to life without parole for crimes he committed as a juvenile. He appealed several times to correct the sentence, but all appeals were denied. In light of the 2016 U.S. Supreme Court's decision in Montgomery v. Louisiana, where the Court held that the rule against mandatory sentences of life without parole for juvenile offenders could be applied retroactively, Mr. Seskey appealed once again. The State argued that he must receive a maximum term of life in prison, but the trial court resentenced him to 13 to 26 years' imprisonment. On appeal, the trial court agreed that Mr. Seskey should immediately be released on parole. The Superior Court of Pennsylvania addressed the question of whether the rules established by the Pennsylvania Supreme Court in Commonwealth v. Batts applied to this case. In Commonwealth v. Batts, the Court held that juvenile defendants convicted of murder prior to June 25, 2012 are subject to a mandatory maximum sentence of life in prison when a sentencing court has determined that a sentence of life without parole is inappropriate when considering the factors established by the U.S. Supreme Court in Miller v. Alabama. Based on this, the Superior Court ruled that the lower court had failed to follow this rule in sentencing Mr. Seskey to 13 to 26 years in prison, so the case was remanded for resentencing.

Summary

Mr. Seskey was found guilty of murder as a teenager and given a life sentence without the possibility of parole. He appealed the sentence several times, but was unsuccessful. In 2016, the U.S. Supreme Court ruled that mandatory life sentences for juvenile offenders could be applied retroactively. Mr. Seskey appealed again. He was resentenced to a term of 13 to 26 years in prison. The trial court then granted him parole.

The Superior Court of Pennsylvania had to decide whether the rules set by the Pennsylvania Supreme Court in Commonwealth v. Batts applied to Mr. Seskey’s case. The Pennsylvania Supreme Court had ruled that juveniles convicted of murder before June 25, 2012, who had been given a life sentence without parole, had to be resentenced to a maximum of life in prison if a judge determined that a life sentence without parole was not appropriate.

The Superior Court determined that the lower court had failed to follow the rules set in Commonwealth v. Batts by sentencing Mr. Seskey to a term of 13 to 26 years. Therefore, the case was sent back to the lower court for a new sentencing.

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Abstract

In this case, a defendant, Mr. Seskey, was convicted of first-degree murder and sentenced to life without parole for crimes he committed as a juvenile. He appealed several times to correct the sentence, but all appeals were denied. In light of the 2016 U.S. Supreme Court's decision in Montgomery v. Louisiana, where the Court held that the rule against mandatory sentences of life without parole for juvenile offenders could be applied retroactively, Mr. Seskey appealed once again. The State argued that he must receive a maximum term of life in prison, but the trial court resentenced him to 13 to 26 years' imprisonment. On appeal, the trial court agreed that Mr. Seskey should immediately be released on parole. The Superior Court of Pennsylvania addressed the question of whether the rules established by the Pennsylvania Supreme Court in Commonwealth v. Batts applied to this case. In Commonwealth v. Batts, the Court held that juvenile defendants convicted of murder prior to June 25, 2012 are subject to a mandatory maximum sentence of life in prison when a sentencing court has determined that a sentence of life without parole is inappropriate when considering the factors established by the U.S. Supreme Court in Miller v. Alabama. Based on this, the Superior Court ruled that the lower court had failed to follow this rule in sentencing Mr. Seskey to 13 to 26 years in prison, so the case was remanded for resentencing.

Summary

Mr. Seskey was found guilty of murder when he was a young person. He was sentenced to life in prison with no chance of getting out. He tried to get his sentence changed many times, but he was unsuccessful.

The Supreme Court said that life in prison without parole is not a fair sentence for young people who commit crimes. So, Mr. Seskey went to court again. He got a new sentence of 13 to 26 years in prison. But then, the court decided he should be released from prison right away.

The court decided that the new sentence was not fair because of a rule about how long people should stay in prison if they committed murder before a certain date. So, Mr. Seskey’s case will go back to court so that a new sentence can be decided.

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Footnotes and Citation

Cite

170 A.3d 1105 (Pa.Super. 2017)

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