State v. Springer
Annotate this CaseIn 1996, Defendant, who was sixteen years old at the time, pleaded guilty and was sentenced to a term of thirty-three years in prison for kidnapping. In 2012, Defendant filed a pro se motion to correct an illegal sentence, arguing that his sentence was unconstitutional based on the United States Supreme Court decisions Roper v. Simmons, Graham v. Florida, and Miller v. Alabama. The circuit court denied the motion. The Supreme Court affirmed, holding that Defendant did not receive life without parole or a de facto life sentence because he had the opportunity for release at age forty-nine, and therefore, Defendant was unable to establish that Roper, Graham, and Miller applied to him.
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