State of Arizona v. Joshua Aston
SummaryOriginal

Summary

Aston (AZ 2023) gets life without parole for murder as a juvenile. He cites Miller v. Alabama for resentencing. The Arizona Supreme Court denies this, stating legislature can create new sentencing schemes.

2023 | State Juristiction

State of Arizona v. Joshua Aston

Keywords LWOP; juvenile life without parole; Miller v. Alabama; juvenile offenders; mandatory life sentences

Abstract

The State of Arizona v. Joshua Aston (2023) involved a challenge to mandatory life sentences for juvenile offenders. Aston, convicted of murder at 16, received a life sentence without the possibility of parole. Citing the U.S. Supreme Court's rulings in Miller v. Alabama (2012) and Montgomery v. Louisiana (2016), which prohibited such sentences, Aston argued his sentence was unconstitutional. The Arizona Court of Appeals agreed and ordered resentencing with the possibility of parole. However, the Arizona Supreme Court reversed, finding the state legislature had a window to enact new sentencing schemes in response to Miller and Montgomery, and Aston was not entitled to resentencing under the prior, now-unconstitutional law.

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Abstract

The State of Arizona v. Joshua Aston (2023) involved a challenge to mandatory life sentences for juvenile offenders. Aston, convicted of murder at 16, received a life sentence without the possibility of parole. Citing the U.S. Supreme Court's rulings in Miller v. Alabama (2012) and Montgomery v. Louisiana (2016), which prohibited such sentences, Aston argued his sentence was unconstitutional. The Arizona Court of Appeals agreed and ordered resentencing with the possibility of parole. However, the Arizona Supreme Court reversed, finding the state legislature had a window to enact new sentencing schemes in response to Miller and Montgomery, and Aston was not entitled to resentencing under the prior, now-unconstitutional law.

In the 2023 case of The State of Arizona v. Joshua Aston, the Arizona Supreme Court addressed the legality of a mandatory life sentence without the possibility of parole (LWOP) imposed on a juvenile offender. Mr. Aston, convicted of murder at age 16, challenged his LWOP sentence citing the precedent established by Miller v. Alabama (2012) and Montgomery v. Louisiana (2016). These U.S. Supreme Court rulings prohibited mandatory LWOP sentences for juveniles. The Arizona Court of Appeals, in agreement with Mr. Aston's argument, determined his sentence unconstitutional and ordered a resentencing hearing that would consider the possibility of parole. This decision, however, was overturned by the Arizona Supreme Court. The state's highest court held that the Arizona legislature was afforded a period to modify sentencing guidelines following Miller and Montgomery. Therefore, Mr. Aston was not eligible for resentencing under the previous, and now deemed unconstitutional, statutory framework.

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Abstract

The State of Arizona v. Joshua Aston (2023) involved a challenge to mandatory life sentences for juvenile offenders. Aston, convicted of murder at 16, received a life sentence without the possibility of parole. Citing the U.S. Supreme Court's rulings in Miller v. Alabama (2012) and Montgomery v. Louisiana (2016), which prohibited such sentences, Aston argued his sentence was unconstitutional. The Arizona Court of Appeals agreed and ordered resentencing with the possibility of parole. However, the Arizona Supreme Court reversed, finding the state legislature had a window to enact new sentencing schemes in response to Miller and Montgomery, and Aston was not entitled to resentencing under the prior, now-unconstitutional law.

The case of Arizona v. Joshua Aston (2023) centered around the legality of mandatory life sentences without parole for individuals who committed crimes as minors. Joshua Aston, convicted of murder at age 16, received such a sentence. Referencing the U.S. Supreme Court decisions in Miller v. Alabama (2012) and Montgomery v. Louisiana (2016), which deemed these types of sentences unconstitutional for juveniles, Aston contested his sentence. The Arizona Court of Appeals sided with Aston, ordering a resentencing hearing that allowed for the possibility of parole. This decision, however, was overturned by the Arizona Supreme Court. The higher court argued that Arizona's legislature had a period to modify sentencing guidelines following the Miller and Montgomery rulings, and Aston's sentencing, while under a now-defunct law, was not eligible for review.

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Abstract

The State of Arizona v. Joshua Aston (2023) involved a challenge to mandatory life sentences for juvenile offenders. Aston, convicted of murder at 16, received a life sentence without the possibility of parole. Citing the U.S. Supreme Court's rulings in Miller v. Alabama (2012) and Montgomery v. Louisiana (2016), which prohibited such sentences, Aston argued his sentence was unconstitutional. The Arizona Court of Appeals agreed and ordered resentencing with the possibility of parole. However, the Arizona Supreme Court reversed, finding the state legislature had a window to enact new sentencing schemes in response to Miller and Montgomery, and Aston was not entitled to resentencing under the prior, now-unconstitutional law.

In Arizona v. Joshua Aston, a man convicted of murder as a teenager fights his life sentence. Aston, who committed the crime at 16, was given life in prison without any chance of parole. He argued that this punishment is unfair based on decisions by the highest court in the U.S.

In two separate cases, Miller v. Alabama (2012) and Montgomery v. Louisiana (2016), the U.S. Supreme Court ruled that forcing juveniles to spend their entire lives in prison is unconstitutional. Aston believes these rulings mean he should have a shot at parole.

The Arizona Court of Appeals initially agreed with Aston. They ordered a new sentencing hearing where he could potentially get parole. However, the Arizona Supreme Court (the highest court in Arizona) overturned this decision. They stated that after the Miller and Montgomery rulings, Arizona's lawmakers had a chance to update the state's sentencing laws but didn't do it in Aston's case. Therefore, even though the old law might now be unconstitutional, Aston isn't eligible for resentencing under it.

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Abstract

The State of Arizona v. Joshua Aston (2023) involved a challenge to mandatory life sentences for juvenile offenders. Aston, convicted of murder at 16, received a life sentence without the possibility of parole. Citing the U.S. Supreme Court's rulings in Miller v. Alabama (2012) and Montgomery v. Louisiana (2016), which prohibited such sentences, Aston argued his sentence was unconstitutional. The Arizona Court of Appeals agreed and ordered resentencing with the possibility of parole. However, the Arizona Supreme Court reversed, finding the state legislature had a window to enact new sentencing schemes in response to Miller and Montgomery, and Aston was not entitled to resentencing under the prior, now-unconstitutional law.

In 2023, a court case in Arizona, State of Arizona v. Joshua Aston, focused on whether teenagers who commit murder should have to spend the rest of their lives in prison. Joshua Aston was found guilty of murder when he was only 16 years old. Because of the law in Arizona at the time, the judge had no choice but to give him a life sentence without any chance of ever getting out of prison.

Joshua argued that his sentence wasn't fair. He pointed to important decisions made by the highest court in the United States in the Miller v. Alabama (2012) and Montgomery v. Louisiana (2016) cases. These decisions said that forcing teenagers to spend their entire lives in prison was a cruel and unusual punishment, which is forbidden by the U.S. Constitution.

A court in Arizona, called the Court of Appeals, agreed with Joshua and said he should be given a new sentence where he might have a chance to get out of prison someday. However, the highest court in Arizona, known as the Arizona Supreme Court, disagreed. They said that after the Miller and Montgomery cases, Arizona's lawmakers had a chance to change the law about sentencing teenagers. Since Joshua was sentenced under the old law, before it was considered unconstitutional, the Supreme Court said he couldn't get a new sentence.

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Footnotes and Citation

Cite

State v. Aston, No. 2 CA-CR 2022-0167-PR (Ariz. Ct. App. Nov. 20, 2023) (unpublished decision)

Highlights