State v. Soto
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Summary

The Court grappled with applying Miller retroactively. Miller banned mandatory LWOP for juveniles. Soto argued his sentence violated the Eighth Amendment. The court considered if Miller should allow Soto and others to be resentenced.

2014 | State Juristiction

State v. Soto

Keywords Eighth Amendment (U.S.); juvenile justice; LWOP; juvenile life without parole; juvenile offenders; cruel and unusual punishment; retroactive application of Miller

Abstract

The case of State of New Hampshire v. Michael Soto (2014) centered around the question of whether a life without parole sentence for Michael Soto, who was convicted of first-degree murder as a teenager, violated the Eighth Amendment's prohibition against cruel and unusual punishment. This case came after the U.S. Supreme Court's ruling in Miller v. Alabama (2012), which banned mandatory life without parole sentences for juveniles. The New Hampshire Supreme Court in this case considered whether Miller should be applied retroactively, allowing Soto and similarly situated individuals to be resentenced with the possibility of parole.

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Abstract

The case of State of New Hampshire v. Michael Soto (2014) centered around the question of whether a life without parole sentence for Michael Soto, who was convicted of first-degree murder as a teenager, violated the Eighth Amendment's prohibition against cruel and unusual punishment. This case came after the U.S. Supreme Court's ruling in Miller v. Alabama (2012), which banned mandatory life without parole sentences for juveniles. The New Hampshire Supreme Court in this case considered whether Miller should be applied retroactively, allowing Soto and similarly situated individuals to be resentenced with the possibility of parole.

The New Hampshire Supreme Court, in State of New Hampshire v. Michael Soto (2014), grappled with the legal implications of Miller v. Alabama (2012) on individuals sentenced to life without parole (LWOP) for crimes committed as minors. The Court specifically addressed whether Miller, which prohibited mandatory LWOP sentences for juveniles, should be applied retroactively. This question held significant weight for Michael Soto, convicted of first-degree murder as a teenager and consequently sentenced to LWOP, as a ruling in favor of retroactivity would necessitate a resentencing hearing with the possibility of parole.

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Abstract

The case of State of New Hampshire v. Michael Soto (2014) centered around the question of whether a life without parole sentence for Michael Soto, who was convicted of first-degree murder as a teenager, violated the Eighth Amendment's prohibition against cruel and unusual punishment. This case came after the U.S. Supreme Court's ruling in Miller v. Alabama (2012), which banned mandatory life without parole sentences for juveniles. The New Hampshire Supreme Court in this case considered whether Miller should be applied retroactively, allowing Soto and similarly situated individuals to be resentenced with the possibility of parole.

The case of State of New Hampshire v. Michael Soto (2014) grappled with the issue of whether sentencing Michael Soto, convicted of first-degree murder as a teenager, to life in prison without the possibility of parole constituted cruel and unusual punishment, violating the Eighth Amendment. This legal challenge arose following the landmark Supreme Court decision in Miller v. Alabama (2012), which prohibited mandatory life sentences without parole for juvenile offenders. The New Hampshire Supreme Court, in Soto's case, deliberated whether the Miller ruling should be applied retroactively. Such a decision would grant Soto, and others in similar situations, the opportunity for resentencing with the possibility of parole.

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Abstract

The case of State of New Hampshire v. Michael Soto (2014) centered around the question of whether a life without parole sentence for Michael Soto, who was convicted of first-degree murder as a teenager, violated the Eighth Amendment's prohibition against cruel and unusual punishment. This case came after the U.S. Supreme Court's ruling in Miller v. Alabama (2012), which banned mandatory life without parole sentences for juveniles. The New Hampshire Supreme Court in this case considered whether Miller should be applied retroactively, allowing Soto and similarly situated individuals to be resentenced with the possibility of parole.

In 2014, the state of New Hampshire tried to figure out if keeping Michael Soto in jail for the rest of his life was fair. Soto had been convicted of first-degree murder as a teenager, and his original sentence didn't give him any chance of parole. However, this was before a big Supreme Court case, Miller v. Alabama (2012), which said that forcing juveniles to serve life without parole was unconstitutional. So, the big question for New Hampshire was whether Miller should apply to older cases like Soto's. If it did, Soto and others like him would get a chance to be resentenced and maybe even have a shot at parole.

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Abstract

The case of State of New Hampshire v. Michael Soto (2014) centered around the question of whether a life without parole sentence for Michael Soto, who was convicted of first-degree murder as a teenager, violated the Eighth Amendment's prohibition against cruel and unusual punishment. This case came after the U.S. Supreme Court's ruling in Miller v. Alabama (2012), which banned mandatory life without parole sentences for juveniles. The New Hampshire Supreme Court in this case considered whether Miller should be applied retroactively, allowing Soto and similarly situated individuals to be resentenced with the possibility of parole.

In 2014, a court in New Hampshire looked at the case of Michael Soto. Soto was convicted of a very serious crime, first-degree murder, when he was still a teenager. He was given a very tough punishment: spending the rest of his life in prison without the chance of ever getting out (parole). The court had to decide if this punishment was fair according to the Eighth Amendment. This amendment says that people can't be given "cruel and unusual punishment."

This case happened after another important case, Miller v. Alabama (2012). In Miller v. Alabama, the highest court in the US, said it was wrong to automatically give teenagers life in prison without parole - it went against the Eighth Amendment. The New Hampshire court had to figure out if the decision in Miller v. Alabama should apply to Michael Soto's case. If so, Soto and other people in similar situations might have a chance to get a new sentence and maybe even have a chance to be released from prison someday.

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Footnotes and Citation

Cite

State v. Soto, 162 N.H. 688 (N.H. 2014)

Highlights