The Maryland Court of Appeals Explains How Supreme Court Precedent on Juvenile Sentencing Applies to Maryland Offenders

Last Summer, in Carter et al. v. State, the Maryland Court of Appeals issued its first ruling on Eighth Amendment challenges arising from the juvenile offender-friendly Supreme Court precedent in Graham v. Florida, 560 U.S. 48 (2010), Miller v. Alabama, 567 U.S. 460 (2012), and Montgomery v. Louisiana, 136 S.Ct. 718 (2016). Although the Court of Appeals decision in Carter did not provide relief to two of the three juvenile offenders whose sentences were being challenged, the decision did interpret the Supreme Court’s precedent more broadly than many other states and federal jurisdictions have done to date. The Carter decision granted relief to the juvenile offender who was serving a 100-year term-of-years sentence with 50 years of parole ineligibility. In so holding, the Court of Appeals stated that forcing a juvenile offender to wait 50 years for a parole hearing is too long to comport with the Eighth Amendment. Notably, the Court of Appeals went even further, beyond saying that 50 years of parole ineligibility was too long, and added that in order for a juvenile offender’s sentence to be constitutional, the period of parole ineligibility would have to be significantly short of the 50-year mark. It suggested that the length of time a juvenile offender could be forced to serve before having his first opportunity for release would vary and depend on a case-by-case analysis. This holding has the potential to impact numerous juvenile offenders convicted in Maryland who are serving lengthy term-of-years sentences with periods of parole ineligibility longer than the standard 15 years required to be served on a life sentence.

Underlying the Court of Appeals’ grant of relief to the aforementioned offender, Carter clarified that the holdings of Graham, Miller, and Montgomery, which place restrictions on the sentences imposed on juveniles, indeed apply to Maryland defendants. Other jurisdictions around the country have interpreted the Supreme Court’s rule much more narrowly, precluding the protections set forth in those cases from applying to any sentences other than ones explicitly labeled as “mandatory life without parole.” Carter held that discretionarily imposed sentences that are de facto life without parole, also require the Miller protections – broadening the group of juvenile offenders who may be impacted by the sentencing restrictions imposed by the Supreme Court.

Nathans & Biddle, LLP is currently litigating cases for several juvenile offenders based on the Carter decision, and we are expecting the Court of Appeals to grant certiorari in additional juvenile sentencing cases over the next year or so, further clarifying the rights of juvenile offenders serving life sentences in Maryland.

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