Abstract
Laycelle White, convicted of murder at 15 years old, appealed his sentence in White v. Premo. He received a lengthy determinate sentence (800 months) that effectively amounted to life without parole. White argued this sentence violated the Eighth Amendment's protection against cruel and unusual punishment, especially for young offenders. He cited the recent Supreme Court case Miller v. Alabama, which limited life sentences for juveniles. The Oregon Supreme Court agreed with White in a 2019 decision. However, the court first had to address whether White's appeal was procedurally barred. The state argued he had not raised the Eighth Amendment claim in his initial post-conviction proceedings. The court ultimately found that White was not procedurally barred because the legal landscape had shifted significantly since his initial conviction due to Miller v. Alabama. On the merits, the court found White's sentence violated the Eighth Amendment as established in Miller v. Alabama. The court remanded the case for a new sentencing hearing that considered White's age at the time of the crime.
Abstract
Laycelle White, convicted of murder at 15 years old, appealed his sentence in White v. Premo. He received a lengthy determinate sentence (800 months) that effectively amounted to life without parole. White argued this sentence violated the Eighth Amendment's protection against cruel and unusual punishment, especially for young offenders. He cited the recent Supreme Court case Miller v. Alabama, which limited life sentences for juveniles. The Oregon Supreme Court agreed with White in a 2019 decision. However, the court first had to address whether White's appeal was procedurally barred. The state argued he had not raised the Eighth Amendment claim in his initial post-conviction proceedings. The court ultimately found that White was not procedurally barred because the legal landscape had shifted significantly since his initial conviction due to Miller v. Alabama. On the merits, the court found White's sentence violated the Eighth Amendment as established in Miller v. Alabama. The court remanded the case for a new sentencing hearing that considered White's age at the time of the crime.
Laycelle White, convicted of murder at age 15, appealed his 800-month sentence, arguing that its determinate nature constituted a de facto life sentence without parole, thus violating the Eighth Amendment's prohibition against cruel and unusual punishment, particularly for juvenile offenders. White's appeal relied heavily on Miller v. Alabama (2012), a landmark Supreme Court ruling that restricted the imposition of life sentences without parole for individuals who committed crimes as minors.
Before addressing the merits of White's Eighth Amendment claim, the Oregon Supreme Court first addressed the State's argument that White's appeal was procedurally barred due to his failure to raise this claim in his initial post-conviction proceedings. The Court, however, determined that White was not procedurally barred because the legal landscape regarding juvenile sentencing had significantly evolved following Miller v. Alabama. On the merits, the Court found White's sentence to be in violation of the Eighth Amendment as articulated in Miller v. Alabama, and remanded the case for resentencing, mandating consideration of White's age at the time of the offense.
Abstract
Laycelle White, convicted of murder at 15 years old, appealed his sentence in White v. Premo. He received a lengthy determinate sentence (800 months) that effectively amounted to life without parole. White argued this sentence violated the Eighth Amendment's protection against cruel and unusual punishment, especially for young offenders. He cited the recent Supreme Court case Miller v. Alabama, which limited life sentences for juveniles. The Oregon Supreme Court agreed with White in a 2019 decision. However, the court first had to address whether White's appeal was procedurally barred. The state argued he had not raised the Eighth Amendment claim in his initial post-conviction proceedings. The court ultimately found that White was not procedurally barred because the legal landscape had shifted significantly since his initial conviction due to Miller v. Alabama. On the merits, the court found White's sentence violated the Eighth Amendment as established in Miller v. Alabama. The court remanded the case for a new sentencing hearing that considered White's age at the time of the crime.
Laycelle White, who was convicted of murder at the age of 15, appealed his 800-month sentence, arguing that it constituted cruel and unusual punishment, violating the Eighth Amendment. This sentence, White argued, effectively amounted to life in prison without the possibility of parole. His appeal relied heavily on the precedent set by Miller v. Alabama, a landmark Supreme Court case that placed limitations on life sentences for minors.
Before addressing White's Eighth Amendment claim, the Oregon Supreme Court first needed to determine if his appeal was procedurally permissible. The state argued that White had failed to raise this constitutional issue in his initial post-conviction proceedings, potentially barring him from doing so now. However, the court ultimately sided with White, concluding that the legal landscape surrounding juvenile sentencing had been significantly altered by Miller v. Alabama, a case decided after White's initial conviction. This shift, the court determined, meant White was not procedurally barred from making his argument.
Turning to the core issue of the case, the Oregon Supreme Court ultimately agreed with White. Citing Miller v. Alabama, the court held that White's sentence was a violation of the Eighth Amendment's prohibition against cruel and unusual punishment. As a result, the court remanded the case back to the lower court, ordering a new sentencing hearing. This new hearing, the court specified, must take into account White's age at the time he committed the crime.
Abstract
Laycelle White, convicted of murder at 15 years old, appealed his sentence in White v. Premo. He received a lengthy determinate sentence (800 months) that effectively amounted to life without parole. White argued this sentence violated the Eighth Amendment's protection against cruel and unusual punishment, especially for young offenders. He cited the recent Supreme Court case Miller v. Alabama, which limited life sentences for juveniles. The Oregon Supreme Court agreed with White in a 2019 decision. However, the court first had to address whether White's appeal was procedurally barred. The state argued he had not raised the Eighth Amendment claim in his initial post-conviction proceedings. The court ultimately found that White was not procedurally barred because the legal landscape had shifted significantly since his initial conviction due to Miller v. Alabama. On the merits, the court found White's sentence violated the Eighth Amendment as established in Miller v. Alabama. The court remanded the case for a new sentencing hearing that considered White's age at the time of the crime.
Laycelle White, who was found guilty of murder when he was only 15 years old, appealed his very long prison sentence (800 months) in the case of White v. Premo. White argued that this sentence, which would basically keep him in prison for the rest of his life, was a violation of his rights. He said it went against the Eighth Amendment, which protects against "cruel and unusual punishment," especially for young people. He pointed to a recent case, Miller v. Alabama, where the Supreme Court said that life sentences for juveniles should be limited.
The highest court in Oregon agreed with White in 2019. But first, they had to figure out if White was even allowed to make this appeal. The state argued that he should have brought up this Eighth Amendment argument earlier, right after his original trial. The court decided that White was allowed to appeal because the laws about sentencing young people had changed a lot since his first trial, thanks to the Miller v. Alabama case. Basically, the court recognized that White and his lawyers had a good reason for not bringing up this argument earlier.
Looking at the specifics of White's case, the Oregon court stated that his sentence was a violation of the Eighth Amendment, just like the Supreme Court had decided in Miller v. Alabama. They sent the case back to the lower court and ordered a new sentencing hearing. This time, the court would have to strongly consider White's age at the time of the crime when deciding on his sentence.
Abstract
Laycelle White, convicted of murder at 15 years old, appealed his sentence in White v. Premo. He received a lengthy determinate sentence (800 months) that effectively amounted to life without parole. White argued this sentence violated the Eighth Amendment's protection against cruel and unusual punishment, especially for young offenders. He cited the recent Supreme Court case Miller v. Alabama, which limited life sentences for juveniles. The Oregon Supreme Court agreed with White in a 2019 decision. However, the court first had to address whether White's appeal was procedurally barred. The state argued he had not raised the Eighth Amendment claim in his initial post-conviction proceedings. The court ultimately found that White was not procedurally barred because the legal landscape had shifted significantly since his initial conviction due to Miller v. Alabama. On the merits, the court found White's sentence violated the Eighth Amendment as established in Miller v. Alabama. The court remanded the case for a new sentencing hearing that considered White's age at the time of the crime.
Laycelle White was only 15 years old when he was convicted of murder. He was given a very long sentence – 800 months in prison. This was like a life sentence, meaning he might never get out of jail. White thought this punishment was too harsh, especially for someone so young. He said it was against the Eighth Amendment of the Constitution, which protects people from cruel and unusual punishment. White pointed to a case called Miller v. Alabama, where the Supreme Court said that life sentences for kids were not always fair.
The Oregon Supreme Court agreed with White in 2019. But first, they had to figure out if he was even allowed to appeal his sentence. The state argued that White should have brought this up earlier. However, the court decided White could appeal. This was because the law about sentencing young people had changed a lot since Miller v. Alabama.
When they finally looked at White's case, the court said his sentence did violate the Eighth Amendment, just like in Miller v. Alabama. They sent the case back to the lower court and said White should get a new sentencing hearing. This time, the court had to consider how old White was when he committed the crime.