Wilson v. State
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The Supreme Court reduced Defendant's sentence imposed in connection with his conviction for two counts of murder, Class B felony armed robbery, and a Class D felony conspiracy to commit criminal gang activity, holding that Defendant's appellate counsel was ineffective on direct appeal by failing to bring an Appellate Rule 7(B) challenge to the appropriateness of Defendant's sentence.
Defendant was sixteen years old when he committed the crimes underlying his convictions. On post-conviction review, Defendant argued that his sentence of 181 years constituted a de facto juvenile life sentence that violated the Eighth Amendment. The post-conviction court denied relief. The Supreme Court revised Defendant's sentence downward to an aggregate 100 years, holding (1) Defendant's original sentence was not unconstitutional because the protections outlined in Miller v. Alabama, 567 U.S. 460 (2012), for juvenile life-without-parole sentences are inapplicable to a term of years sentence; but (2) appellate counsel's failure to challenge the sentence's appropriateness amounted to deficient performance, and Defendant was prejudiced by the failure. In the interest of judicial economy, the Supreme Court conducted a review of the sentence under Appellate Rule 7(B) and revised the sentence downward.
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