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October 8, 2009

Minnesota Supreme Court rejects constitutional arguments against LWOP sentence for 17-year-old murderer

A helpful reader forwarded to me today's Minnesota Supreme Court decision in State v. Martin, No. A07-1262 (Minn. Oct. 8, 2009) (available here).  The official syllabus in the Martin case describes one of its holdings in this way: "The punishment of life in prison without the possibility of release for a juvenile who was 17 years of age when he committed the offense was not cruel or unusual punishment in violation of the United States or Minnesota Constitutions." 

The body of the opinion details that the Minnesota Supreme Court in 1999 upheld a juve LWOP sentence against a constitutional challenge, and it also notes that the defendant in this case "was only six weeks from his eighteenth birthday when he shot" and killed a rival gang member.  After reviewing the constitutional arguments made by the defendant, the Minnesota Supreme Court concludes that "Martin has failed to carry his heavy burden of demonstrating a compelling reason to overturn [our prior ruling].  Nor did Martin make any showing that this punishment was disproportionate as applied to him. We hold that the punishment ... is not unconstitutional as applied to Martin."

October 8, 2009 at 02:54 PM | Permalink


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Aren't Grahm and Sullivan limited specifically to non-murder convictions? If my memory on that point is correct I don't see this outcome being particularly surprising. I don't even see why the court would hold the decision while waiting for SCOTUS to answer a different question.

Posted by: Soronel Haetir | Oct 8, 2009 4:27:49 PM

You are right Soronel. But if the defendants win in Graham and Sullivan AND if the opinions are not real specific about limiting the ruling to non-capital crimes, cases like Martin could be impacted. That said, I share you view that there was not a strong reason for the Minnesota Supreme Court to wait to issue this ruling.

Posted by: Doug B. | Oct 9, 2009 8:45:03 AM

I am a trial judge. I followed the constituional debate about life without the possibility of parole for juveniles a bit more closely because not to long ago I presided over a case involving a juvenile faced with that possibility and a motion to attack that sentence in the event of conviction. The jury found the juvenile guility of a lesser crime so I never had to rule. As I have thought about the issue two things seemed significant.First, at that age it is difficult to make an intelligent and rational choice about plea bargaining. "If I'm going to spend 25 years in prison and get out in my 40s I might as well be dead so no deals!" The difference in the proof required for life without parole and some long determinate sentence isn't always clear and so the level of maturity to make these kind of decisions needs to be pretty sophisticated. The second issue is the trust we are willing to give to future generations long after we have died. Life with the possibility of parole does not mandate release. It does give a future generation the opportunity to reflect, exercise compasion if appropriate or not to.

Posted by: Kevin Burke | Oct 15, 2009 10:13:20 AM

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