Abstract
In State v. Mares (2014), the Wyoming Supreme Court addressed the constitutionality of a juvenile life without parole sentence imposed in 1995. The case arose after the U.S. Supreme Court's ruling in Miller v. Alabama (2012), which declared such sentences unconstitutional for some juveniles. The Wyoming court adopted the Teague v. Lane test to determine retroactivity and concluded Miller did apply retroactively. However, the court further determined that intervening amendments to Wyoming's parole statutes had already rendered the defendant's sentence one of life with the possibility of parole, making the challenge moot.
Abstract
In State v. Mares (2014), the Wyoming Supreme Court addressed the constitutionality of a juvenile life without parole sentence imposed in 1995. The case arose after the U.S. Supreme Court's ruling in Miller v. Alabama (2012), which declared such sentences unconstitutional for some juveniles. The Wyoming court adopted the Teague v. Lane test to determine retroactivity and concluded Miller did apply retroactively. However, the court further determined that intervening amendments to Wyoming's parole statutes had already rendered the defendant's sentence one of life with the possibility of parole, making the challenge moot.
In the 2014 case of State v. Mares, the Wyoming Supreme Court grappled with the implications of Miller v. Alabama (2012) on a juvenile life without parole (LWOP) sentence imposed in 1995. The Miller decision had deemed mandatory LWOP sentences for certain juvenile offenders unconstitutional. To ascertain the retroactivity of Miller, the Wyoming court employed the framework established in Teague v. Lane. Ultimately, the court found Miller to be retroactive. However, it also determined that subsequent modifications to Wyoming's parole statutes had effectively transformed the defendant's sentence into one of life with the possibility of parole, thus rendering the legal challenge moot.
Abstract
In State v. Mares (2014), the Wyoming Supreme Court addressed the constitutionality of a juvenile life without parole sentence imposed in 1995. The case arose after the U.S. Supreme Court's ruling in Miller v. Alabama (2012), which declared such sentences unconstitutional for some juveniles. The Wyoming court adopted the Teague v. Lane test to determine retroactivity and concluded Miller did apply retroactively. However, the court further determined that intervening amendments to Wyoming's parole statutes had already rendered the defendant's sentence one of life with the possibility of parole, making the challenge moot.
In the 2014 case of State v. Mares, the Wyoming Supreme Court grappled with the legality of a life sentence without parole given to a juvenile in 1995. This review became necessary after the landmark U.S. Supreme Court decision in Miller v. Alabama (2012), which found mandatory life without parole sentences unconstitutional for certain juvenile offenders. To figure out if the Miller decision applied to older cases like Mares', the Wyoming court used a legal framework called the Teague v. Lane test for retroactivity. Ultimately, the court decided that Miller did apply retroactively. However, there was a twist. The court also found that subsequent changes to Wyoming's parole laws meant that the defendant's sentence was already effectively one of life with the possibility of parole. This rendered the defendant's legal challenge pointless, or "moot" in legal terms.
Abstract
In State v. Mares (2014), the Wyoming Supreme Court addressed the constitutionality of a juvenile life without parole sentence imposed in 1995. The case arose after the U.S. Supreme Court's ruling in Miller v. Alabama (2012), which declared such sentences unconstitutional for some juveniles. The Wyoming court adopted the Teague v. Lane test to determine retroactivity and concluded Miller did apply retroactively. However, the court further determined that intervening amendments to Wyoming's parole statutes had already rendered the defendant's sentence one of life with the possibility of parole, making the challenge moot.
In 2014, the Wyoming Supreme Court looked at the case of State v. Mares. This case was about whether a man named Mr. Mares, who was given a life sentence without parole for a crime he committed as a teenager in 1995, could challenge his sentence. The U.S. Supreme Court had recently decided in Miller v. Alabama (2012) that life sentences without parole for some young offenders were unconstitutional.
The Wyoming court used a legal test called the Teague v. Lane test to figure out if the Miller decision applied to older cases like Mr. Mares's. They decided it did. However, there was a catch. Wyoming had changed its parole laws since Mr. Mares was sentenced. Because of these changes, his sentence was no longer considered a "life without parole" sentence, but rather a life sentence with the possibility of parole. This made his challenge to the original sentence unnecessary.
Abstract
In State v. Mares (2014), the Wyoming Supreme Court addressed the constitutionality of a juvenile life without parole sentence imposed in 1995. The case arose after the U.S. Supreme Court's ruling in Miller v. Alabama (2012), which declared such sentences unconstitutional for some juveniles. The Wyoming court adopted the Teague v. Lane test to determine retroactivity and concluded Miller did apply retroactively. However, the court further determined that intervening amendments to Wyoming's parole statutes had already rendered the defendant's sentence one of life with the possibility of parole, making the challenge moot.
In 2014, the Wyoming Supreme Court looked at the case of State v. Mares. Mr. Mares was given a very serious sentence when he was young - he was told he would stay in prison for his entire life, with no chance of ever getting out. But in 2012, the U.S. Supreme Court (the most important court in the country) decided that kind of sentence wasn't fair for some young people. They said everyone should have at least a chance to show they've changed and deserve to go free someday.
The Wyoming court had to decide if this new rule about sentences applied to Mr. Mares, even though his sentence happened many years ago. They used a special legal test to decide and said, "Yes, this new rule does apply to older cases like Mr. Mares'."
However, here's where things get interesting. The Wyoming court realized that since Mr. Mares' sentence, Wyoming had changed its own laws about parole (a way to get out of prison early for good behavior). These new laws meant that Mr. Mares' sentence was actually no longer a "life without parole" sentence anymore. Because of that, the court said there was no need to change his sentence - it was already following the rules.