State v. Long
SummaryOriginal

Summary

Ohio Supreme Court required consideration of youth and rehabilitation before JLWOP for juveniles in State v. Long (2014). Long's sentence vacated for resentencing, but court didn't mandate release.

2014 | State Juristiction

State v. Long

Keywords juvenile offender sentencing; juvenile life without parole; LWOP; Eighth Amendment (U.S.); proportionality principle; Miller v. Alabama; resentencing; rehabilitation potential of youth

Abstract

State v. Long (2014) centered on the sentencing of Eric Long, a juvenile offender who received a life sentence without parole (JLWOP) for participating in multiple murders. Following the landmark U.S. Supreme Court case Miller v. Alabama (2012), which prohibited mandatory JLWOP sentences, Long argued his sentence violated the Eighth Amendment's proportionality principle. The Eighth Amendment prohibits punishments that are cruel and unusual, and the principle requires sentences to be proportionate to the crime, especially for juveniles. The Ohio Supreme Court agreed with Long in part. The court acknowledged Miller v. Alabama and ruled that sentencing courts must consider a juvenile offender's youth and potential for rehabilitation as mitigating factors before imposing JLWOP. However, the court remanded Long's case for resentencing without directly ordering his release.

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Abstract

State v. Long (2014) centered on the sentencing of Eric Long, a juvenile offender who received a life sentence without parole (JLWOP) for participating in multiple murders. Following the landmark U.S. Supreme Court case Miller v. Alabama (2012), which prohibited mandatory JLWOP sentences, Long argued his sentence violated the Eighth Amendment's proportionality principle. The Eighth Amendment prohibits punishments that are cruel and unusual, and the principle requires sentences to be proportionate to the crime, especially for juveniles. The Ohio Supreme Court agreed with Long in part. The court acknowledged Miller v. Alabama and ruled that sentencing courts must consider a juvenile offender's youth and potential for rehabilitation as mitigating factors before imposing JLWOP. However, the court remanded Long's case for resentencing without directly ordering his release.

In the case of State v. Long (2014), the Ohio Supreme Court addressed the sentencing of Eric Long, a juvenile offender who received a life sentence without the possibility of parole (JLWOP) for his involvement in multiple homicides. Following the precedent established in Miller v. Alabama (2012), where the U.S. Supreme Court deemed mandatory JLWOP sentences unconstitutional, Long argued that his sentence constituted a violation of the Eighth Amendment's prohibition against cruel and unusual punishment, specifically its proportionality principle. This principle mandates that the severity of a sentence must be commensurate with the offense, particularly for juvenile offenders.

The Ohio Supreme Court rendered a partial decision in favor of Long. Acknowledging the precedent set by Miller v. Alabama, the court held that sentencing courts must consider a juvenile offender's youth and capacity for rehabilitation as mitigating factors before imposing a JLWOP sentence. However, the court stopped short of ordering Long's release, instead remanding the case for resentencing in light of these factors.

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Abstract

State v. Long (2014) centered on the sentencing of Eric Long, a juvenile offender who received a life sentence without parole (JLWOP) for participating in multiple murders. Following the landmark U.S. Supreme Court case Miller v. Alabama (2012), which prohibited mandatory JLWOP sentences, Long argued his sentence violated the Eighth Amendment's proportionality principle. The Eighth Amendment prohibits punishments that are cruel and unusual, and the principle requires sentences to be proportionate to the crime, especially for juveniles. The Ohio Supreme Court agreed with Long in part. The court acknowledged Miller v. Alabama and ruled that sentencing courts must consider a juvenile offender's youth and potential for rehabilitation as mitigating factors before imposing JLWOP. However, the court remanded Long's case for resentencing without directly ordering his release.

The State v. Long (2014) case revolved around the life sentence without parole (JLWOP) given to Eric Long, a juvenile who participated in several murders. This case occurred after the pivotal Supreme Court ruling in Miller v. Alabama (2012), which deemed mandatory JLWOP sentences unconstitutional. Long argued his sentence went against the Eighth Amendment's proportionality principle, which prohibits "cruel and unusual punishment" and mandates that sentences, particularly for minors, must be fitting to the crime.

The Ohio Supreme Court partially agreed with Long. Citing Miller v. Alabama, the court determined that judges must consider a young offender's age and capacity for rehabilitation as mitigating factors before handing down a JLWOP sentence. However, the court stopped short of ordering Long's release, instead sending his case back to the lower court for a new sentencing hearing.

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Abstract

State v. Long (2014) centered on the sentencing of Eric Long, a juvenile offender who received a life sentence without parole (JLWOP) for participating in multiple murders. Following the landmark U.S. Supreme Court case Miller v. Alabama (2012), which prohibited mandatory JLWOP sentences, Long argued his sentence violated the Eighth Amendment's proportionality principle. The Eighth Amendment prohibits punishments that are cruel and unusual, and the principle requires sentences to be proportionate to the crime, especially for juveniles. The Ohio Supreme Court agreed with Long in part. The court acknowledged Miller v. Alabama and ruled that sentencing courts must consider a juvenile offender's youth and potential for rehabilitation as mitigating factors before imposing JLWOP. However, the court remanded Long's case for resentencing without directly ordering his release.

In the State v. Long case (2014), a teenager named Eric Long was given a life sentence without the possibility of parole (JLWOP) for his role in several murders. This harsh sentence came under fire after the big Supreme Court case Miller v. Alabama (2012), which said automatic JLWOP sentences weren't allowed. Long's lawyers argued that his punishment went against the Eighth Amendment, which bans "cruel and unusual" punishments. They said that sentencing should always be fair and make sense considering the crime, especially for young people.

The Ohio Supreme Court agreed with part of Long's argument. They acknowledged the Miller v. Alabama decision and said that judges have to think about a young person's age and chance for change before handing down a JLWOP sentence. However, they didn't set Long free. Instead, they sent his case back to be sentenced again.

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Abstract

State v. Long (2014) centered on the sentencing of Eric Long, a juvenile offender who received a life sentence without parole (JLWOP) for participating in multiple murders. Following the landmark U.S. Supreme Court case Miller v. Alabama (2012), which prohibited mandatory JLWOP sentences, Long argued his sentence violated the Eighth Amendment's proportionality principle. The Eighth Amendment prohibits punishments that are cruel and unusual, and the principle requires sentences to be proportionate to the crime, especially for juveniles. The Ohio Supreme Court agreed with Long in part. The court acknowledged Miller v. Alabama and ruled that sentencing courts must consider a juvenile offender's youth and potential for rehabilitation as mitigating factors before imposing JLWOP. However, the court remanded Long's case for resentencing without directly ordering his release.

A young man named Eric Long was given a very serious sentence – life in prison without the chance to ever be released – for his part in several murders. This sentence happened before a big court decision, Miller v. Alabama (2012), which decided automatic life sentences with no chance of parole were no longer allowed for minors. Because of that decision, in the case of State v. Long in 2014, Long argued that his sentence, according to the Eighth Amendment, wasn't fair. The Eighth Amendment is a rule that says punishments can't be mean or unusual, and they have to fit the crime.

The top court in Ohio agreed with part of Long's argument. They knew about the Miller v. Alabama decision and stated that judges had to consider a person's age and their potential to change before giving them life in prison without parole. Even though they agreed with that part, they didn't let Long out of prison. Instead, they sent his case back to be looked at again for a possibly different sentence.

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Footnotes and Citation

Cite

State v. Long, 138 Ohio St.3d 478 (Ohio 2014)

Highlights