State v. NathanAnnotate this Case
In connection with a home-invasion robbery and murder, Nathan, 16 years old, was convicted on 26 counts. Pursuant to RSMo 565.020.2, the court sentenced Nathan to life in prison without the possibility of parole plus five life sentences and five 15-year sentences, to be served consecutively. While Nathan's appeal was pending, the U.S. Supreme Court decided, in Miller v. Alabama, that "the Eighth Amendment forbids a sentencing scheme that mandates life in prison without possibility of parole for juvenile offenders." In compliance with the Missouri Supreme Court's instructions on remand, the circuit court entered a finding of guilt for second-degree murder and for armed criminal action in connection with second-degree murder. The jury recommended a life sentence for the second-degree murder conviction, a 30-year sentence for the first-degree robbery conviction, a 15-year sentence for kidnapping, and three life sentences for the related armed criminal action convictions. Nathan requested resentencing by a jury on the 20 convictions that were not part of the remand, claiming a Brady violation because the state failed to disclose, before his original waiver of jury sentencing, a police report detailing an investigation into alleged sexual abuse committed against him. The court rejected his arguments and imposed the jury-recommended sentences, to run consecutively. On appeal, Nathan argued the combined effect of his consecutive sentences amounted to the functional equivalent of life in prison without the possibility of parole. The Missouri Supreme Court disagreed and affirmed.