Martin v. Symmes, No. 13-3676 (8th Cir. 2015)
Annotate this CaseA Minnesota jury convicted Martin of first-degree murder, committed at age 17. Martin received a mandatory life sentence without possibility of release. The Minnesota Supreme Court affirmed and rejected a challenge to the jury’s composition under Batson. Martin filed a habeas petition under 28 U.S.C. 2254. While it was pending, the U.S. Supreme Court held that mandatory life sentences without parole for defendants who commit homicide before age 18 violate the Eighth Amendment. Martin argued that Miller applied retroactively to him. The district court denied the petition. The Eighth Circuit affirmed. Miller does not apply retroactively on collateral review. The Minnesota Supreme Court did not unreasonably determine that the trial court properly rejected Martin’s Batson challenge.
Court Description: Prisoner case - Habeas. In Miller v. Alabama, 132 S. Ct. 2455 (2012), the Supreme Court announced a procedural rule that is not of watershed magnitude and, as such, the decision does not apply retroactively on collateral review; Batson challenge rejected.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.