State v. Brown
SimpleOriginal
2013 | State Juristiction

State v. Brown

Keywords juvenile offender; juvenile life without parole; JLWOP; non-homicide offense; Graham v. Florida; cumulative sentences

Abstract

This case involved a defendant who was convicted of kidnapping and armed robbery at age 16 and sentenced to multiple sentences for the multiple offenses which cumulatively matched or exceeded his life expectancy. In light of the U.S. Supreme Court decision in Graham v. Florida, where the Court held that life without parole was prohibited for juvenile offenders who did not commit homicide, the defendant appealed his sentences. The Supreme Court of Louisiana held that because this defendant had been sentenced for multiple offenses, resulting in multiple sentences, Graham v. Florida did not apply. Their reasoning was that Graham v. Florida was meant to prohibit juvenile offenders who committed non-homicide offenses from being given a single sentence of life without parole, and that it did not apply to juvenile offenders convicted and sentenced for multiple offenses and given multiple sentences that just happened to cumulatively total an amount of years that could be a life sentence.

Open Case as PDF

Abstract

This case involved a defendant who was convicted of kidnapping and armed robbery at age 16 and sentenced to multiple sentences for the multiple offenses which cumulatively matched or exceeded his life expectancy. In light of the U.S. Supreme Court decision in Graham v. Florida, where the Court held that life without parole was prohibited for juvenile offenders who did not commit homicide, the defendant appealed his sentences. The Supreme Court of Louisiana held that because this defendant had been sentenced for multiple offenses, resulting in multiple sentences, Graham v. Florida did not apply. Their reasoning was that Graham v. Florida was meant to prohibit juvenile offenders who committed non-homicide offenses from being given a single sentence of life without parole, and that it did not apply to juvenile offenders convicted and sentenced for multiple offenses and given multiple sentences that just happened to cumulatively total an amount of years that could be a life sentence.

Summary

This case concerns a defendant convicted of kidnapping and armed robbery at the age of sixteen. The defendant received multiple sentences for these offenses, which, when combined, equated to or exceeded their life expectancy. Following the U.S. Supreme Court’s ruling in Graham v. Florida, which prohibited life without parole sentences for non-homicide juvenile offenders, the defendant appealed their sentence. The Supreme Court of Louisiana upheld the original sentence, reasoning that Graham v. Florida applied only to single sentences of life without parole and not multiple sentences that, when combined, resulted in a life sentence.

Open Case as PDF

Abstract

This case involved a defendant who was convicted of kidnapping and armed robbery at age 16 and sentenced to multiple sentences for the multiple offenses which cumulatively matched or exceeded his life expectancy. In light of the U.S. Supreme Court decision in Graham v. Florida, where the Court held that life without parole was prohibited for juvenile offenders who did not commit homicide, the defendant appealed his sentences. The Supreme Court of Louisiana held that because this defendant had been sentenced for multiple offenses, resulting in multiple sentences, Graham v. Florida did not apply. Their reasoning was that Graham v. Florida was meant to prohibit juvenile offenders who committed non-homicide offenses from being given a single sentence of life without parole, and that it did not apply to juvenile offenders convicted and sentenced for multiple offenses and given multiple sentences that just happened to cumulatively total an amount of years that could be a life sentence.

Summary

This case involved a defendant who was convicted of kidnapping and armed robbery at the age of 16 and sentenced to multiple sentences for the multiple offenses. The cumulative length of these sentences matched or exceeded his life expectancy.

The defendant appealed his sentences in light of the U.S. Supreme Court decision in Graham v. Florida. In this case, the Court ruled that life without parole was unconstitutional for juvenile offenders who did not commit homicide.

The Supreme Court of Louisiana ruled that Graham v. Florida did not apply to this defendant because he was sentenced for multiple offenses, resulting in multiple sentences. The Louisiana court reasoned that Graham v. Florida was intended to prohibit juvenile offenders who committed non-homicide offenses from being given a single sentence of life without parole. The court concluded that the ruling did not apply to cases where a juvenile offender was convicted and sentenced for multiple offenses, even if the cumulative total of the sentences amounted to a life sentence.

Open Case as PDF

Abstract

This case involved a defendant who was convicted of kidnapping and armed robbery at age 16 and sentenced to multiple sentences for the multiple offenses which cumulatively matched or exceeded his life expectancy. In light of the U.S. Supreme Court decision in Graham v. Florida, where the Court held that life without parole was prohibited for juvenile offenders who did not commit homicide, the defendant appealed his sentences. The Supreme Court of Louisiana held that because this defendant had been sentenced for multiple offenses, resulting in multiple sentences, Graham v. Florida did not apply. Their reasoning was that Graham v. Florida was meant to prohibit juvenile offenders who committed non-homicide offenses from being given a single sentence of life without parole, and that it did not apply to juvenile offenders convicted and sentenced for multiple offenses and given multiple sentences that just happened to cumulatively total an amount of years that could be a life sentence.

Summary

This case involved a 16-year-old defendant convicted of kidnapping and armed robbery. The defendant received multiple sentences for these offenses, adding up to a term longer than his life expectancy.

The defendant appealed his sentences, arguing that they violated the U.S. Supreme Court decision in Graham v. Florida. In Graham v. Florida, the Court ruled that life without parole sentences were unconstitutional for juvenile offenders who didn't commit murder.

The Louisiana Supreme Court disagreed, stating that the defendant's multiple sentences, even if they equaled a life sentence, did not violate Graham v. Florida. The Court argued that Graham v. Florida specifically addressed single life-without-parole sentences for non-homicide crimes, not multiple sentences that, when combined, could result in a lifetime in prison.

Open Case as PDF

Abstract

This case involved a defendant who was convicted of kidnapping and armed robbery at age 16 and sentenced to multiple sentences for the multiple offenses which cumulatively matched or exceeded his life expectancy. In light of the U.S. Supreme Court decision in Graham v. Florida, where the Court held that life without parole was prohibited for juvenile offenders who did not commit homicide, the defendant appealed his sentences. The Supreme Court of Louisiana held that because this defendant had been sentenced for multiple offenses, resulting in multiple sentences, Graham v. Florida did not apply. Their reasoning was that Graham v. Florida was meant to prohibit juvenile offenders who committed non-homicide offenses from being given a single sentence of life without parole, and that it did not apply to juvenile offenders convicted and sentenced for multiple offenses and given multiple sentences that just happened to cumulatively total an amount of years that could be a life sentence.

Summary

A 16-year-old boy was found guilty of kidnapping and robbery with a gun. He was given multiple punishments that added up to a very long time in prison, almost as long as a lifetime.

The boy's lawyers argued that he shouldn't have to spend his entire life in prison because of a Supreme Court decision that said young people who didn't kill anyone couldn't be locked up forever.

However, the Louisiana Supreme Court disagreed. They said that because the boy was found guilty of multiple crimes, his punishment wasn't a single life sentence, but many shorter sentences that added up to a long time.

Open Case as PDF

Footnotes and Citation

Cite

118 So.3d 332 (La. 2013)

Highlights