In re Brooks
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Summary

17-year-old Carl Brooks received a de facto life sentence for crimes in 1978. The Washington Supreme Court ruled he deserved a new hearing due to changes in juvenile sentencing, considering his potential for rehabilitation as a youth.

2021 | State Juristiction

In re Brooks

Keywords juvenile sentencing; de facto life sentence; rehabilitation of juveniles; Eighth Amendment (U.S.); cruel and unusual punishment; Washington State Supreme Court

Abstract

Carl Brooks, convicted of violent crimes as a teenager in 1978, received multiple life sentences with a combined minimum term of 90 years. This effectively denied him any meaningful chance of release. The Washington Supreme Court considered whether a recent Supreme Court decision limiting life sentences for juveniles (Miller v. Alabama) applied retroactively to Brooks' case. The court ruled in Brooks' favor, finding the state's "Miller fix" statute applied. Brooks was entitled to a new hearing that considered his potential for rehabilitation as a youth and the possibility of an earlier release.

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Abstract

Carl Brooks, convicted of violent crimes as a teenager in 1978, received multiple life sentences with a combined minimum term of 90 years. This effectively denied him any meaningful chance of release. The Washington Supreme Court considered whether a recent Supreme Court decision limiting life sentences for juveniles (Miller v. Alabama) applied retroactively to Brooks' case. The court ruled in Brooks' favor, finding the state's "Miller fix" statute applied. Brooks was entitled to a new hearing that considered his potential for rehabilitation as a youth and the possibility of an earlier release.

In the case of Carl Brooks, who received multiple life sentences with a minimum term of 90 years for violent crimes committed as a teenager in 1978, the Washington Supreme Court addressed the retroactivity of Miller v. Alabama. The Miller decision established limitations on life sentences imposed on juveniles. The court ruled that Washington's "Miller fix" statute, enacted in response to Miller, applied retroactively to Brooks' case. Consequently, Brooks is entitled to a resentencing hearing. This hearing must consider his capacity for rehabilitation as a juvenile and the possibility of an earlier release.

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Abstract

Carl Brooks, convicted of violent crimes as a teenager in 1978, received multiple life sentences with a combined minimum term of 90 years. This effectively denied him any meaningful chance of release. The Washington Supreme Court considered whether a recent Supreme Court decision limiting life sentences for juveniles (Miller v. Alabama) applied retroactively to Brooks' case. The court ruled in Brooks' favor, finding the state's "Miller fix" statute applied. Brooks was entitled to a new hearing that considered his potential for rehabilitation as a youth and the possibility of an earlier release.

Carl Brooks, found guilty of violent offenses in 1978 as a teenager, was given multiple life sentences totaling a minimum of 90 years. This essentially eliminated any realistic possibility of parole. However, a recent Supreme Court ruling in Miller v. Alabama restricted the use of life sentences for minors. This led the Washington Supreme Court to examine whether Miller v. Alabama could be applied retroactively to Brooks' case. Ultimately, the court sided with Brooks, determining that the state's "Miller fix" statute was applicable. Consequently, Brooks is now eligible for a new sentencing hearing. This hearing will take into account his capacity for rehabilitation as a young offender and the potential for an earlier release.

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Abstract

Carl Brooks, convicted of violent crimes as a teenager in 1978, received multiple life sentences with a combined minimum term of 90 years. This effectively denied him any meaningful chance of release. The Washington Supreme Court considered whether a recent Supreme Court decision limiting life sentences for juveniles (Miller v. Alabama) applied retroactively to Brooks' case. The court ruled in Brooks' favor, finding the state's "Miller fix" statute applied. Brooks was entitled to a new hearing that considered his potential for rehabilitation as a youth and the possibility of an earlier release.

Carl Brooks, a man who committed serious crimes as a teenager back in 1978, was given a very long prison sentence. He was told he would be in prison for at least 90 years, which basically meant he had no hope of ever getting out. However, the highest court in Washington state recently looked at his case again. They were deciding if a new rule from the US Supreme Court (in a case called Miller v. Alabama) about sentencing young offenders could be applied to older cases like Brooks'. This new rule said that judges had to consider that young people can change and might deserve a chance to get out of prison someday. The Washington court agreed with Brooks, saying the state's law about how to apply the Miller rule meant Brooks deserved a new hearing. At this hearing, the court will look at whether Brooks has changed for the better while in prison and if he might be safe to release back into society.

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Abstract

Carl Brooks, convicted of violent crimes as a teenager in 1978, received multiple life sentences with a combined minimum term of 90 years. This effectively denied him any meaningful chance of release. The Washington Supreme Court considered whether a recent Supreme Court decision limiting life sentences for juveniles (Miller v. Alabama) applied retroactively to Brooks' case. The court ruled in Brooks' favor, finding the state's "Miller fix" statute applied. Brooks was entitled to a new hearing that considered his potential for rehabilitation as a youth and the possibility of an earlier release.

Carl Brooks was a teenager in 1978 when he was found guilty of some very serious crimes and sent to jail for a very long time. The judge gave him a sentence that meant he would have to stay in jail for at least 90 years. But, a few years ago, the highest court in the whole country (called the Supreme Court) decided that judges shouldn't give such long sentences to kids.

Carl's lawyers said that the new rule should apply to Carl, even though his sentence happened a long time ago. The highest court in Washington state agreed with Carl's lawyers. They said that because of the new rule, Carl should have another chance to show that he has changed and deserves to be released from jail earlier.

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Footnotes and Citation

Cite

In re Pers. Restraint of Brooks, 197 Wash. 2d 94 (Wa. 2021).

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