Dennis v. Georgia
Annotate this CaseIn 1998, a 17-year-old Robert Dennis pled guilty to several charges, including malice murder, in connection with the 1997 shooting death of Louise Carter. Dennis was sentenced, in relevant part to this appeal, to life in prison without the possibility of parole for malice murder. In 2015, the State filed a motion to amend Dennis’ sentence based on the United States Supreme Court’s decision in “Miller v. Alabama.” After a resentencing hearing, the trial court reduced Dennis’s malice murder sentence from life without the possibility of parole to life with the possibility of parole. Dennis appealed pro se that resentencing ruling, challenging the trial court’s authority to resentence him. However, finding that the 1998 sentence was made void by “Miller,” and subject to a challenge on Eighth Amendment grounds at any time. Finding that indeed, the trial court had authority to resentence, the Supreme Court affirmed the new sentence.
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