Robinson v. State (Majority, with Concurring and Dissenting)Annotate this Case
The Supreme Court reversed the order of the circuit court denying Appellant a resentencing hearing and imposing a sentence of life with parole eligibility pursuant to the Fair Sentencing of Minors Act of 2017 (the Act), holding that Appellant was entitled to resentencing in accordance with the Court’s decision in Harris v. State, 547 S.W.3d 64.
In 1983, Appellant pled guilty to capital murder. Appellant was seventeen years old at the time of the murder and received a mandatory sentence of life without parole. Following the United States Supreme Court’s decision in Miller v. Alabama, 467 U.S. 460, 479 (2012), Appellant filed a petition for habeas corpus arguing that his sentence was unconstitutional. The circuit court granted the petition, vacated the sentence, and remanded Appellant’s case for resentencing. Although Appellant’s sentence had been vacated before the Act was enacted, the circuit court relied on the Act’s provision in resentencing him to life imprisonment with the possibility of parole after thirty years. The Supreme Court reversed, holding (1) based on this Court’s decision in Harris, the circuit court erred in applying the Act to Appellant’s case; and (2) Appellant was entitled to a hearing to present Miller evidence for consideration upon resentencing.