People v. Rainer
SummaryOriginal

Summary

Colorado Supreme Court upheld lengthy sentence for juvenile offender Rainer (State v. People, 2017). Court distinguished Miller v. Alabama, finding it didn't apply to Rainer's term-of-years sentence with a (possible) chance of parole.

2017 | State Juristiction

People v. Rainer

Keywords juvenile LWOP; Eighth Amendment (U.S.); Miller v. Alabama; ineligibility for parole; aggregate sentence

Abstract

The case of State of the People of the State of Colorado v. Rainer (2017) involved Atorrus Leon Rainer's challenge to his lengthy sentence for crimes committed as a juvenile. Rainer received an aggregate term-of-years sentence exceeding 40 years, effectively resulting in potential ineligibility for parole. He argued this sentence violated the Eighth Amendment's proportionality principle, citing the landmark case Miller v. Alabama (2010). Miller v. Alabama prohibited mandatory life sentences without parole for juvenile offenders. The Colorado Supreme Court disagreed with Rainer. The court acknowledged Miller v. Alabama but distinguished Rainer's case. They reasoned that Miller v. Alabama addressed mandatory life sentences, whereas Rainer received a term-of-years sentence with a possibility (though unlikely) of parole. The court determined Miller v. Alabama did not directly apply to Rainer's situation and declined to invalidate his sentence based solely on its length.

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Abstract

The case of State of the People of the State of Colorado v. Rainer (2017) involved Atorrus Leon Rainer's challenge to his lengthy sentence for crimes committed as a juvenile. Rainer received an aggregate term-of-years sentence exceeding 40 years, effectively resulting in potential ineligibility for parole. He argued this sentence violated the Eighth Amendment's proportionality principle, citing the landmark case Miller v. Alabama (2010). Miller v. Alabama prohibited mandatory life sentences without parole for juvenile offenders. The Colorado Supreme Court disagreed with Rainer. The court acknowledged Miller v. Alabama but distinguished Rainer's case. They reasoned that Miller v. Alabama addressed mandatory life sentences, whereas Rainer received a term-of-years sentence with a possibility (though unlikely) of parole. The court determined Miller v. Alabama did not directly apply to Rainer's situation and declined to invalidate his sentence based solely on its length.

The case of People v. Rainer (2017) before the Colorado Supreme Court concerned the issue of lengthy sentences for juvenile offenders. The defendant, Atorrus Leon Rainer, challenged his aggregate sentence, exceeding 40 years, which effectively made him ineligible for parole until late in life. Relying on Miller v. Alabama (2010), Rainer argued that his sentence constituted a violation of the Eighth Amendment's prohibition against cruel and unusual punishment due to its disproportionate nature. The Miller precedent prohibits mandatory life sentences without parole for juveniles.

The Colorado Supreme Court, however, rejected Rainer's argument. While acknowledging the significance of Miller v. Alabama, the court distinguished it from the case at hand. The court emphasized that Miller specifically addressed mandatory life sentences without the possibility of parole. Conversely, Rainer received a term-of-years sentence, which, although presenting a remote likelihood, did not preclude the possibility of parole. Consequently, the court determined that the Miller precedent did not have direct bearing on Rainer's situation and declined to invalidate his sentence based solely on its length.

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Abstract

The case of State of the People of the State of Colorado v. Rainer (2017) involved Atorrus Leon Rainer's challenge to his lengthy sentence for crimes committed as a juvenile. Rainer received an aggregate term-of-years sentence exceeding 40 years, effectively resulting in potential ineligibility for parole. He argued this sentence violated the Eighth Amendment's proportionality principle, citing the landmark case Miller v. Alabama (2010). Miller v. Alabama prohibited mandatory life sentences without parole for juvenile offenders. The Colorado Supreme Court disagreed with Rainer. The court acknowledged Miller v. Alabama but distinguished Rainer's case. They reasoned that Miller v. Alabama addressed mandatory life sentences, whereas Rainer received a term-of-years sentence with a possibility (though unlikely) of parole. The court determined Miller v. Alabama did not directly apply to Rainer's situation and declined to invalidate his sentence based solely on its length.

The 2017 case of State of the People of the State of Colorado v. Rainer centered around Atorrus Leon Rainer's argument against his substantial prison sentence for offenses he committed as a minor. Rainer received a combined sentence of over 40 years, essentially translating to a potential life sentence without parole. He claimed this punishment was unconstitutional under the Eighth Amendment's protection against cruel and unusual punishment, citing the precedent set by Miller v. Alabama (2010). In the Miller case, the Supreme Court ruled that mandatory life sentences without parole for juveniles were unconstitutional.

However, the Colorado Supreme Court disagreed with Rainer's argument. While acknowledging the significance of Miller v. Alabama, the court differentiated Rainer's case. They emphasized that Miller v. Alabama specifically addressed mandatory life sentences, whereas Rainer received a determinate sentence with a theoretical chance of parole, however improbable. Ultimately, the court concluded that Miller v. Alabama didn't directly apply to Rainer's situation and refused to overturn his sentence based solely on its length.

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Abstract

The case of State of the People of the State of Colorado v. Rainer (2017) involved Atorrus Leon Rainer's challenge to his lengthy sentence for crimes committed as a juvenile. Rainer received an aggregate term-of-years sentence exceeding 40 years, effectively resulting in potential ineligibility for parole. He argued this sentence violated the Eighth Amendment's proportionality principle, citing the landmark case Miller v. Alabama (2010). Miller v. Alabama prohibited mandatory life sentences without parole for juvenile offenders. The Colorado Supreme Court disagreed with Rainer. The court acknowledged Miller v. Alabama but distinguished Rainer's case. They reasoned that Miller v. Alabama addressed mandatory life sentences, whereas Rainer received a term-of-years sentence with a possibility (though unlikely) of parole. The court determined Miller v. Alabama did not directly apply to Rainer's situation and declined to invalidate his sentence based solely on its length.

In 2017, Atorrus Leon Rainer appealed his really long prison sentence to the Colorado Supreme Court. Rainer was given more than 40 years for crimes he committed as a teenager, which basically meant he probably wouldn't get parole. He argued that such a long sentence wasn't fair and went against the Eighth Amendment, which bans cruel and unusual punishment. He pointed to a famous case, Miller v. Alabama (2010), where the Supreme Court said that juveniles couldn't be automatically sentenced to life without parole.

The Colorado Supreme Court disagreed with Rainer. They said that even though Miller v. Alabama was important, it didn't apply to Rainer's case. In Miller, the issue was a mandatory life sentence, meaning the juvenile had no chance at release. Rainer, on the other hand, got a specific number of years and could technically be eligible for parole someday, even if it was unlikely. Because of that difference, the court decided to uphold Rainer's sentence.

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Abstract

The case of State of the People of the State of Colorado v. Rainer (2017) involved Atorrus Leon Rainer's challenge to his lengthy sentence for crimes committed as a juvenile. Rainer received an aggregate term-of-years sentence exceeding 40 years, effectively resulting in potential ineligibility for parole. He argued this sentence violated the Eighth Amendment's proportionality principle, citing the landmark case Miller v. Alabama (2010). Miller v. Alabama prohibited mandatory life sentences without parole for juvenile offenders. The Colorado Supreme Court disagreed with Rainer. The court acknowledged Miller v. Alabama but distinguished Rainer's case. They reasoned that Miller v. Alabama addressed mandatory life sentences, whereas Rainer received a term-of-years sentence with a possibility (though unlikely) of parole. The court determined Miller v. Alabama did not directly apply to Rainer's situation and declined to invalidate his sentence based solely on its length.

In 2017, a man named Atorrus Rainer told the Colorado Supreme Court that his punishment wasn't fair. When he was young, he had broken the law and was given a very, very long sentence - over 40 years. This meant he might have to stay in jail for most of his life and would be very old before he could get out. Rainer said this was like being told he would be in jail for life, and that it was unfair. He pointed to a big court case, Miller v. Alabama, where the Court said it was unconstitutional to give kids a life sentence without any chance of ever getting out.

The Colorado Supreme Court saw things differently than Rainer. They agreed that Miller v. Alabama was an important case, but they said it was different from Rainer's situation. In Miller, the sentences were for life without any chance of parole. Rainer, however, got a very long sentence, but he might be able to get parole someday, even if it was unlikely. So, the court decided that what happened in Miller v. Alabama didn't change what happened in Rainer's case, and he had to stay in jail.

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Footnotes and Citation

Cite

People v. Rainer, 394 P.3d 1141 (Colo. 2017)

Highlights