United States v. Sierra, No. 15-2220 (2d Cir. 2019)
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The Second Circuit affirmed defendants' sentences of mandatory minimum terms of life imprisonment applicable to convictions for murder in aid of racketeering. Defendants argued that because they were between the ages of 18 and 22 years old when the murders were committed, a mandatory life sentence was cruel and unusual in violation of the Eighth Amendment.
The court held that defendants' age-based Eighth Amendment challenges to their sentences failed, because the Supreme Court has chosen to draw the constitutional line at the age of 18 for mandatory minimum life sentences. Furthermore, Defendant Lopez's argument that his sentence violates the Eighth Amendment because he did not commit the murders directly was foreclosed by Supreme Court precedent in Harmelin v. Michigan, 501 U.S. 957 (1991).
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