State v. Shanahan
SummaryOriginal

Summary

2019 | State Juristiction

State v. Shanahan

Keywords juvenile offender; juvenile sentencing; de facto life without parole; juvenile life without parole; JLWOP; Miller v. Alabama

Abstract

This case before the Supreme Court of Idaho was a case of first impression on the question of whether a juvenile offender convicted of homicide who receives an indeterminate life sentence with a long fixed term is entitled to resentencing considerations in light of the ruling in Miller v. Alabama. Mr. Shanahan argued that since his sentencing in 1997, there had been significant changes in the law related to sentencing juvenile offenders, thus making his sentence unconstitutional. The Court agreed that a sentence which amounts to a de facto life sentence due to its length violates the Eighth Amendment under Miller v. Alabama, but disagreed that Mr. Shanahan's sentence constituted a de facto life sentence. The Court therefore held that Mr. Shanahan's sentence was not illegal even in light of Miller v. Alabama.

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Abstract

This case before the Supreme Court of Idaho was a case of first impression on the question of whether a juvenile offender convicted of homicide who receives an indeterminate life sentence with a long fixed term is entitled to resentencing considerations in light of the ruling in Miller v. Alabama. Mr. Shanahan argued that since his sentencing in 1997, there had been significant changes in the law related to sentencing juvenile offenders, thus making his sentence unconstitutional. The Court agreed that a sentence which amounts to a de facto life sentence due to its length violates the Eighth Amendment under Miller v. Alabama, but disagreed that Mr. Shanahan's sentence constituted a de facto life sentence. The Court therefore held that Mr. Shanahan's sentence was not illegal even in light of Miller v. Alabama.

Summary

This case presented the Idaho Supreme Court with a novel question concerning the implications of Miller v. Alabama on indeterminate life sentences for juvenile offenders convicted of homicide. The appellant, Mr. Shanahan, argued that his 1997 sentence, characterized by a lengthy fixed term, violated the Eighth Amendment due to subsequent developments in the law governing juvenile sentencing.

The Court acknowledged the principle established in Miller v. Alabama that sentences amounting to de facto life imprisonment for juveniles are unconstitutional. However, the Court ultimately determined that Mr. Shanahan's sentence did not constitute a de facto life sentence, thereby concluding that it remained legal despite the precedent set in Miller v. Alabama.

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Abstract

This case before the Supreme Court of Idaho was a case of first impression on the question of whether a juvenile offender convicted of homicide who receives an indeterminate life sentence with a long fixed term is entitled to resentencing considerations in light of the ruling in Miller v. Alabama. Mr. Shanahan argued that since his sentencing in 1997, there had been significant changes in the law related to sentencing juvenile offenders, thus making his sentence unconstitutional. The Court agreed that a sentence which amounts to a de facto life sentence due to its length violates the Eighth Amendment under Miller v. Alabama, but disagreed that Mr. Shanahan's sentence constituted a de facto life sentence. The Court therefore held that Mr. Shanahan's sentence was not illegal even in light of Miller v. Alabama.

Summary

This Idaho Supreme Court case addressed the issue of whether a juvenile offender sentenced to an indeterminate life sentence with a long fixed term should be considered for resentencing in light of the Miller v. Alabama ruling.

The defendant, Mr. Shanahan, argued that legal changes since his 1997 sentencing, specifically related to juvenile offenders, rendered his sentence unconstitutional. The Court acknowledged that sentences amounting to de facto life terms due to their length violate the Eighth Amendment, as established in Miller v. Alabama. However, the Court determined that Mr. Shanahan's sentence did not constitute a de facto life sentence and, therefore, remained legal even after Miller v. Alabama.

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Abstract

This case before the Supreme Court of Idaho was a case of first impression on the question of whether a juvenile offender convicted of homicide who receives an indeterminate life sentence with a long fixed term is entitled to resentencing considerations in light of the ruling in Miller v. Alabama. Mr. Shanahan argued that since his sentencing in 1997, there had been significant changes in the law related to sentencing juvenile offenders, thus making his sentence unconstitutional. The Court agreed that a sentence which amounts to a de facto life sentence due to its length violates the Eighth Amendment under Miller v. Alabama, but disagreed that Mr. Shanahan's sentence constituted a de facto life sentence. The Court therefore held that Mr. Shanahan's sentence was not illegal even in light of Miller v. Alabama.

Summary

The Idaho Supreme Court considered a case about a juvenile offender sentenced to life in prison with a long fixed term. This was the first time the court had to decide if this kind of sentence was legal under a new ruling called Miller v. Alabama.

The offender, Mr. Shanahan, argued that since his sentencing in 1997, the laws about sentencing juveniles had changed, making his sentence illegal.

The court agreed that very long sentences for juveniles can be cruel and unusual punishment, violating the Eighth Amendment, as Miller v. Alabama had ruled. However, they disagreed that Mr. Shanahan's sentence was long enough to be considered a de facto life sentence. Therefore, the court decided that Mr. Shanahan's sentence was still legal, even after Miller v. Alabama.

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Abstract

This case before the Supreme Court of Idaho was a case of first impression on the question of whether a juvenile offender convicted of homicide who receives an indeterminate life sentence with a long fixed term is entitled to resentencing considerations in light of the ruling in Miller v. Alabama. Mr. Shanahan argued that since his sentencing in 1997, there had been significant changes in the law related to sentencing juvenile offenders, thus making his sentence unconstitutional. The Court agreed that a sentence which amounts to a de facto life sentence due to its length violates the Eighth Amendment under Miller v. Alabama, but disagreed that Mr. Shanahan's sentence constituted a de facto life sentence. The Court therefore held that Mr. Shanahan's sentence was not illegal even in light of Miller v. Alabama.

Summary

This case was about whether a young person who committed a crime and got a very long prison sentence should get a chance to have their sentence looked at again.

The person, Mr. Shanahan, said that because of changes in the law since his sentence in 1997, his sentence was no longer fair.

The court said that very long sentences for young people can be unfair, but Mr. Shanahan's sentence wasn't that long. So, the court said Mr. Shanahan's sentence was still okay, even though the law had changed.

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Footnotes and Citation

Cite

165 Idaho 343, 445 P.3d 152, 159 (2019)

Highlights