Keefe v. State
SummaryOriginal

Summary

Keefe, sentenced to life without parole at 17 for murder, appealed based on Eighth Amendment. Montana SC agreed in 2021, citing Miller v. Alabama, and ordered a new sentencing hearing considering his youth at the time of the crime.

2021 | State Juristiction

Keefe v. State

Keywords LWOP; juvenile life without parole; Miller factors; juvenile life without parole; juvenile offenders

Abstract

State of Montana v. Keefe involved Steven Wayne Keefe, who was sentenced to life in prison without parole for three murders he committed at 17 years old. Keefe appealed the sentence arguing it violated the Eighth Amendment's protection against cruel and unusual punishment, especially for young offenders. The Montana Supreme Court agreed in a 2021 decision, citing Miller v. Alabama, which limited life without parole sentences for juveniles. The court ordered a new sentencing hearing considering Keefe's age at the time of the crime.

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Abstract

State of Montana v. Keefe involved Steven Wayne Keefe, who was sentenced to life in prison without parole for three murders he committed at 17 years old. Keefe appealed the sentence arguing it violated the Eighth Amendment's protection against cruel and unusual punishment, especially for young offenders. The Montana Supreme Court agreed in a 2021 decision, citing Miller v. Alabama, which limited life without parole sentences for juveniles. The court ordered a new sentencing hearing considering Keefe's age at the time of the crime.

In the legal case of State of Montana v. Steven Wayne Keefe, the defendant, having committed three homicides at the age of seventeen, received a sentence of life imprisonment without the possibility of parole. Keefe subsequently filed an appeal, asserting that the sentence imposed constituted a violation of the Eighth Amendment's prohibition against cruel and unusual punishment, particularly in its application to juvenile offenders. The Montana Supreme Court, in a 2021 ruling, concurred with Keefe's argument, citing Miller v. Alabama, a landmark case that established limitations on the imposition of life without parole sentences for individuals who commit crimes while under the age of eighteen. Consequently, the court vacated Keefe's original sentence and remanded the case for a new sentencing hearing, mandating that Keefe's age at the time of the offenses be a mitigating factor for consideration.

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Abstract

State of Montana v. Keefe involved Steven Wayne Keefe, who was sentenced to life in prison without parole for three murders he committed at 17 years old. Keefe appealed the sentence arguing it violated the Eighth Amendment's protection against cruel and unusual punishment, especially for young offenders. The Montana Supreme Court agreed in a 2021 decision, citing Miller v. Alabama, which limited life without parole sentences for juveniles. The court ordered a new sentencing hearing considering Keefe's age at the time of the crime.

In the case of State of Montana v. Steven Wayne Keefe, the defendant, who received a life sentence without the possibility of parole for three murders committed at the age of 17, challenged his sentence. Keefe argued that sentencing a juvenile to life without parole constituted cruel and unusual punishment, a violation of the Eighth Amendment. The Montana Supreme Court, in a 2021 ruling, agreed with Keefe, citing Miller v. Alabama, a landmark case that placed limitations on life without parole sentences for minors. Consequently, the court vacated Keefe's original sentence and ordered a new sentencing hearing that would factor in his age at the time of the offenses.

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Abstract

State of Montana v. Keefe involved Steven Wayne Keefe, who was sentenced to life in prison without parole for three murders he committed at 17 years old. Keefe appealed the sentence arguing it violated the Eighth Amendment's protection against cruel and unusual punishment, especially for young offenders. The Montana Supreme Court agreed in a 2021 decision, citing Miller v. Alabama, which limited life without parole sentences for juveniles. The court ordered a new sentencing hearing considering Keefe's age at the time of the crime.

Steven Wayne Keefe, who was 17 when he killed three people, was given a life sentence without the possibility of parole. Keefe appealed this sentence, claiming it was a cruel and unusual punishment, especially for someone his age at the time of the crime. He argued that this sentence went against the Eighth Amendment. The Montana Supreme Court agreed with Keefe in 2021. They referenced a case, Miller v. Alabama, that made it clear that juveniles should not automatically receive life without parole. The court ordered a new sentencing hearing that would take into consideration Keefe's age when he committed the murders.

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Abstract

State of Montana v. Keefe involved Steven Wayne Keefe, who was sentenced to life in prison without parole for three murders he committed at 17 years old. Keefe appealed the sentence arguing it violated the Eighth Amendment's protection against cruel and unusual punishment, especially for young offenders. The Montana Supreme Court agreed in a 2021 decision, citing Miller v. Alabama, which limited life without parole sentences for juveniles. The court ordered a new sentencing hearing considering Keefe's age at the time of the crime.

Steven Wayne Keefe was a teenager, just 17 years old, when he did something very wrong – he committed three murders. Because of this, a judge decided he should spend the rest of his life in prison, with no chance of ever getting out.

Keefe thought this punishment was way too harsh, especially since he was so young when he committed the crimes. He argued that such a sentence went against the rules of the United States, specifically the part that says people can't be punished in cruel and unusual ways.

The highest court in Montana agreed with Keefe. They said that because he was so young when he committed the crimes, giving him life in prison without any chance of parole wasn't fair. They pointed to another important court case, Miller v. Alabama, which said that judges need to think very carefully before giving young people such serious sentences. The court ordered a new sentencing hearing where they considered how old Keefe was when he committed the crimes.

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Footnotes and Citation

Cite

State v. Keefe, 2021 MT 8, 403 Mont. 1, 478 P.3d 830 (Mont. 2021)

Highlights