Falcon v. State
SummaryOriginal

Summary

Florida SC rules Miller v. Alabama, banning mandatory LWOP for juveniles, applies retroactively. Falcon, sentenced as a juvenile to life for murder, gets a new sentencing hearing that considers her age and the crime's circumstances.

2015 | State Juristiction

Falcon v. State

Keywords retroactive application of Miller; Miller v. Alabama; LWOP; mandatory life sentence; Eighth Amendment (U.S.); cruel and unusual punishment

Abstract

In Falcon v. State (2015), the Florida Supreme Court addressed the retroactive application of the U.S. Supreme Court's decision in Miller v. Alabama (2012). Miller held that mandatory life sentences without parole for juvenile homicide offenders were unconstitutional. The Florida court determined that Miller applied retroactively to all individuals in Florida serving such sentences. This meant they were entitled to resentencing hearings that considered their youth and the specific circumstances of their crimes. The case involved Tiffany Falcon, who received a life sentence without parole for a murder she committed at 15. The court reversed her sentence and remanded the case for resentencing under Florida statutes informed by Miller.

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Abstract

In Falcon v. State (2015), the Florida Supreme Court addressed the retroactive application of the U.S. Supreme Court's decision in Miller v. Alabama (2012). Miller held that mandatory life sentences without parole for juvenile homicide offenders were unconstitutional. The Florida court determined that Miller applied retroactively to all individuals in Florida serving such sentences. This meant they were entitled to resentencing hearings that considered their youth and the specific circumstances of their crimes. The case involved Tiffany Falcon, who received a life sentence without parole for a murder she committed at 15. The court reversed her sentence and remanded the case for resentencing under Florida statutes informed by Miller.

In the 2015 case of Falcon v. State, the Florida Supreme Court addressed the issue of retroactivity regarding the U.S. Supreme Court's holding in Miller v. Alabama (2012). The Miller decision declared mandatory life sentences without the possibility of parole for juvenile homicide offenders unconstitutional. The Florida Supreme Court determined that the Miller ruling applied retroactively to all individuals serving such sentences in Florida. Consequently, these individuals were entitled to new sentencing hearings that factored in their age at the time of the offense and the specific circumstances of their crimes. This case involved Tiffany Falcon, who had been sentenced to life without parole for a murder committed at age 15. The Florida Supreme Court reversed Falcon's sentence and remanded her case for resentencing in accordance with Florida statutes, as informed by the Miller decision.

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Abstract

In Falcon v. State (2015), the Florida Supreme Court addressed the retroactive application of the U.S. Supreme Court's decision in Miller v. Alabama (2012). Miller held that mandatory life sentences without parole for juvenile homicide offenders were unconstitutional. The Florida court determined that Miller applied retroactively to all individuals in Florida serving such sentences. This meant they were entitled to resentencing hearings that considered their youth and the specific circumstances of their crimes. The case involved Tiffany Falcon, who received a life sentence without parole for a murder she committed at 15. The court reversed her sentence and remanded the case for resentencing under Florida statutes informed by Miller.

In the 2015 case of Falcon v. State, the Florida Supreme Court addressed how the U.S. Supreme Court's ruling in Miller v. Alabama (2012) impacted individuals already serving sentences. The Miller decision deemed mandatory life sentences without parole unconstitutional for juveniles convicted of homicide. The Florida Supreme Court decided that the Miller ruling applied retroactively to all Florida inmates serving such sentences. This ruling meant these individuals had a right to new sentencing hearings where their age at the time of the crime and the specifics of their cases would be considered. The case involved Tiffany Falcon, who received a life sentence without the possibility of parole for a murder she committed at age 15. The court overturned her sentence and sent the case back to the lower court for a new sentencing hearing that aligned with the Miller ruling and relevant Florida laws.

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Abstract

In Falcon v. State (2015), the Florida Supreme Court addressed the retroactive application of the U.S. Supreme Court's decision in Miller v. Alabama (2012). Miller held that mandatory life sentences without parole for juvenile homicide offenders were unconstitutional. The Florida court determined that Miller applied retroactively to all individuals in Florida serving such sentences. This meant they were entitled to resentencing hearings that considered their youth and the specific circumstances of their crimes. The case involved Tiffany Falcon, who received a life sentence without parole for a murder she committed at 15. The court reversed her sentence and remanded the case for resentencing under Florida statutes informed by Miller.

In 2012, the U.S. Supreme Court decided in Miller v. Alabama that forcing someone who committed murder as a kid to spend the rest of their life in prison without the chance of parole was wrong. Because of this decision, the Florida Supreme Court, in Falcon v. State (2015), said that everyone in Florida prisons serving this type of sentence had to have their sentence looked at again.

This case was about Tiffany Falcon, who was given a life sentence without parole for a murder she committed at 15 years old. The court decided her sentence wasn't fair and said that the court that sentenced her needed to have another hearing to decide on a new sentence using Florida laws that were updated because of Miller.

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Abstract

In Falcon v. State (2015), the Florida Supreme Court addressed the retroactive application of the U.S. Supreme Court's decision in Miller v. Alabama (2012). Miller held that mandatory life sentences without parole for juvenile homicide offenders were unconstitutional. The Florida court determined that Miller applied retroactively to all individuals in Florida serving such sentences. This meant they were entitled to resentencing hearings that considered their youth and the specific circumstances of their crimes. The case involved Tiffany Falcon, who received a life sentence without parole for a murder she committed at 15. The court reversed her sentence and remanded the case for resentencing under Florida statutes informed by Miller.

In 2012, the most important court in the U.S. decided that it was wrong to automatically sentence teenagers to life in prison without the chance of ever getting out if they committed a very serious crime. This decision was made in a case called Miller v. Alabama.

Later, the Florida Supreme Court looked at a case called Falcon v. State (2015). They had to decide if this new rule from Miller v. Alabama should apply to teenagers who were already serving life sentences in Florida. The court decided it should.

Tiffany Falcon was one of these teenagers. She was given a life sentence without the possibility of parole for a murder she committed when she was only 15. Because of the decision in Falcon v. State, the court said her sentence had to be reviewed. She would get a new hearing where a judge would consider that she was so young when the crime happened.

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Footnotes and Citation

Cite

Falcon v. State, 162 So. 3d 954 (Fla. 2015)

Highlights