State v. Charles
Annotate this CaseDefendant was convicted of first-degree murder and received a mandatory sentence of life in prison. Defendant was fourteen years old when he committed the offense. After the United States Supreme Court issued Miller v. Alabama, Defendant filed a motion to have his sentence corrected. After a hearing, the sentencing court resentenced Defendant to ninety-two years in prison. The Supreme Court affirmed, holding (1) a ninety-two-year sentence is not categorically unconstitutional for a fourteen-year-old child; (2) because Defendant had the opportunity for release at age sixty, his sentence was not the legal equivalent of a life sentence without parole; (3) the sentencing court properly considered the mitigating qualities of youth set forth in Miller; (4) Defendant’s sentence was not grossly disproportionate to the gravity of the offense; and (5) the sentencing court did not commit prejudicial error when it permitted an oral victim-impact statement by an individual outside the statutory definition of a victim.
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