State ex rel Moran v. Louisiana
Annotate this CaseA jury found defendant Alden Morgan, committed armed robbery at age 17. Following return of the guilty verdict, the district court sentenced him to 99 years imprisonment at hard labor without benefit of parole, probation, or suspension of sentence. After being denied relief on direct review, defendant filed a motion to correct an illegal sentence in light of recent developments in Eighth Amendment jurisprudence pertaining to the sentencing of juveniles. The Louisiana Supreme Court granted the defendant’s writ application to determine whether the defendant’s 99-year sentence was an effective life sentence and was, therefore, illegal under the Supreme Court’s decision in "Graham v. Florida," (560 U.S. 48 (2010)). The Louisiana Court held that a 99-year sentence without parole was illegal because it did not provide the defendant “with a meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation.” Accordingly, the Court amended defendant’s sentence to delete the restriction on parole eligibility.
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