Jackson v. State
Annotate this CaseAppellant was charged with first-degree premeditated murder. On the date of the murder, Appellant was seventeen years old. The district court sentenced Appellant to life imprisonment without the possibility of release (LWOR). Appellant later filed a petition for postconviction relief claiming that he was entitled to a new trial because an eyewitness recanted his trial testimony and that his mandatory sentence of LWOR should be reversed based on Miller v. Alabama. The postconviction court denied Appellant’s petition after an evidentiary hearing. The Supreme Court (1) affirmed in part, holding that the postconviction court did not abuse its discretion by ruling that the eyewitness’s out-of-court statements were not admissible under Minn. R. Evid. 804(b)(3); but (2) vacated Appellant’s LWOR sentence because the mandatory statutory scheme under which his sentence was imposed was unconstitutional as applied according to Montgomery v. Louisiana. Remanded for resentencing.
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