Garcia v. State
SummaryOriginal

Summary

North Dakota Supreme Court denies juvenile offender's appeal for resentencing under new law due to non-retroactive application.

2017 | State Juristiction

Garcia v. State

Keywords Eighth Amendment (U.S.); juvenile offender; murder; cruel and unusual punishment; LWOP; juvenile life without parole; Miller v. Alabama

Abstract

Barry Garcia, convicted of murder as a juvenile in 1996 and sentenced to life without parole, appealed in 2016 after the U.S. Supreme Court rulings in Miller v. Alabama (2012) and Montgomery v. Louisiana (2016) cast doubt on the constitutionality of such sentences for juveniles. Garcia argued his sentence violated those standards. While North Dakota passed a new law in 2017 allowing for potential relief in such cases, the Court ruled it couldn't be applied retroactively to Garcia's case.

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Abstract

Barry Garcia, convicted of murder as a juvenile in 1996 and sentenced to life without parole, appealed in 2016 after the U.S. Supreme Court rulings in Miller v. Alabama (2012) and Montgomery v. Louisiana (2016) cast doubt on the constitutionality of such sentences for juveniles. Garcia argued his sentence violated those standards. While North Dakota passed a new law in 2017 allowing for potential relief in such cases, the Court ruled it couldn't be applied retroactively to Garcia's case.

Barry Garcia, found guilty of murder as a teenager in 1996, received a life sentence without the possibility of parole. In 2016, he challenged his sentence, citing the U.S. Supreme Court decisions in Miller v. Alabama (2012) and Montgomery v. Louisiana (2016). These rulings questioned the constitutionality of life without parole sentences for juveniles. Garcia contended that his sentence violated these standards. Although North Dakota enacted legislation in 2017 providing potential relief for similar cases, the Court determined that this law could not be applied retroactively to Garcia's case.

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Abstract

Barry Garcia, convicted of murder as a juvenile in 1996 and sentenced to life without parole, appealed in 2016 after the U.S. Supreme Court rulings in Miller v. Alabama (2012) and Montgomery v. Louisiana (2016) cast doubt on the constitutionality of such sentences for juveniles. Garcia argued his sentence violated those standards. While North Dakota passed a new law in 2017 allowing for potential relief in such cases, the Court ruled it couldn't be applied retroactively to Garcia's case.

Barry Garcia, convicted of murder as a juvenile in 1996 and sentenced to life in prison without the possibility of parole, appealed his sentence in 2016. The basis for his appeal was the U.S. Supreme Court rulings in Miller v. Alabama (2012) and Montgomery v. Louisiana (2016). These rulings questioned the constitutionality of life-without-parole sentences for juveniles, arguing that such sentences fail to consider the unique developmental characteristics of young offenders. Garcia argued his sentence violated these standards.

While North Dakota passed a new law in 2017 to potentially provide relief for individuals in similar situations, the Court ruled that this law could not be applied retroactively to Garcia's case. This means that the law could not be used to re-evaluate Garcia's sentence even though it was passed after his original conviction.

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Abstract

Barry Garcia, convicted of murder as a juvenile in 1996 and sentenced to life without parole, appealed in 2016 after the U.S. Supreme Court rulings in Miller v. Alabama (2012) and Montgomery v. Louisiana (2016) cast doubt on the constitutionality of such sentences for juveniles. Garcia argued his sentence violated those standards. While North Dakota passed a new law in 2017 allowing for potential relief in such cases, the Court ruled it couldn't be applied retroactively to Garcia's case.

Barry Garcia was found guilty of murder as a teenager in 1996 and given a life sentence without the possibility of parole. In 2016, he appealed his sentence. He argued that his sentence was unconstitutional because of Supreme Court decisions in Miller v. Alabama (2012) and Montgomery v. Louisiana (2016). These cases cast doubt on whether life sentences without parole are fair for juveniles. North Dakota passed a law in 2017 that could have helped people in situations like Garcia's, but the Court ruled it couldn't be applied to cases that were already decided.

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Abstract

Barry Garcia, convicted of murder as a juvenile in 1996 and sentenced to life without parole, appealed in 2016 after the U.S. Supreme Court rulings in Miller v. Alabama (2012) and Montgomery v. Louisiana (2016) cast doubt on the constitutionality of such sentences for juveniles. Garcia argued his sentence violated those standards. While North Dakota passed a new law in 2017 allowing for potential relief in such cases, the Court ruled it couldn't be applied retroactively to Garcia's case.

In 1996, Barry Garcia was sent to prison for life (without the chance of parole) for a murder he committed when he was just a teenager.

In 2016, Garcia tried to get his sentence changed. The Supreme Court had decided in two recent and important cases that it's not fair to give minors automatic life in prison without the chance of parole. These cases were Miller v. Alabama (2012) and Montgomery v. Louisiana (2016). Because of this, Garcia argued that his sentence wasn't fair and went against his constitutional rights. North Dakota, the state where Garcia was from, had even made a new law in 2017 that said people sent to prison as minors should have a chance of parole.

But the court said the new law couldn't help Garcia because it was made after he got his sentence.

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Footnotes and Citation

Cite

Garcia v. State, 903 N.W.2d 503 (N.D. 2017)

Highlights