Atkins v. Crowell, No. 18-6012 (6th Cir. 2019)
Annotate this CaseA Tennessee jury convicted Atkins of murdering his stepfather in 2000 when he was 16 years old. A state court imposed a life sentence that renders Atkins eligible for release after at least 51 years’ imprisonment. His conviction and sentence were affirmed on appeal. The Supreme Court later held, in “Miller,” that a sentence of “mandatory life without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment’s prohibition on ‘cruel and unusual punishments,’” a decision that applies retroactively. Atkins argued that the life sentence he received as a 16-year-old also qualified as a “cruel and unusual” punishment under the Eighth Amendment. A state appellate court rejected his claim. The district court denied relief in his federal habeas petition. The Sixth Circuit affirmed, stating that 28 U.S.C. 2254(d)(1) prohibits a federal habeas court from upending a state criminal judgment unless a state court’s rejection of a constitutional claim was “contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States.” Reasonable people can debate a sentencing policy that did not give the 16- year-old Atkins any opportunity for release for 51 years but the state appellate court reasonably distinguished Miller.
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