The California Supreme Court ruled last week that sentencing a juvenile offender to 110 years in prison qualifies as cruel and unusual punishment, reports the Los Angeles Times.
So what should be the upper limit for juvenile offenders?
In 2007, Rodrigo Caballero, a 16-year-old, opened fire on three teenage boys who were members of a rival gang.
Adrian Bautista, Carlos Vargas, and Vincent Valle, members of the Val Verde Park Gang, were rounding a street corner on foot when Caballero jumped out of a green Toyota and yelled out the name of his gang. Vargas responded with a rival gang yell, and Caballero began shooting at the group. Neither Vargas nor Valle were hit by the gunfire, but Bautista was hit in the upper back.
A jury later convicted Caballero of three counts of attempted murder.
Caballero, a diagnosed schizophrenic, testified in his own behalf after he was treated with antipsychotic medication. He told the jury both that he "was straight trying to kill somebody" and that he did not intend to kill anyone. The trial court sentenced Caballero to 15 years to life for each of the attempted murder counts, plus two consecutive 20-year-to-life terms for two of the firearm enhancements, and 25 years to life for the third firearm enhancement.
His total sentence was 110 years to life, which meant that he would not be eligible for parole in his lifetime. The Court of Appeal affirmed the trial court's judgment in its entirety.
Last week, the California Supreme Court reversed Caballero's sentence in a unanimous decision.
Relying on the Supreme Court's decision in Graham v. Florida -- holding that the Eighth Amendment prohibits states from sentencing a juvenile convicted of nonhomicide offenses to life imprisonment without the possibility of parole -- the state's highest court concluded that sentencing a juvenile offender for a nonhomicide offense to a term of years with a parole eligibility date that falls outside the juvenile offender's natural life expectancy constitutes cruel and unusual punishment in violation of the Eighth Amendment.
Justice Ming W. Chin, wrote for the court, "Although proper authorities may later determine that youths should remain incarcerated for their natural lives, the state may not deprive them at sentencing of a meaningful opportunity to demonstrate their rehabilitation and fitness to reenter society in the future."
The court, however, declined to define a specific limit on a juvenile offender's term, noting, "Because every case will be different, we will not provide trial courts with a precise time frame for setting these future parole hearings in a nonhomicide case. However, the sentence must not violate the defendant's Eighth Amendment rights and must provide him or her a 'meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation' under Graham's mandate."
- People v. Caballero (FindLaw's CaseLaw)
- SORNA Trumps Juvenile Delinquent's Privacy Concerns (FindLaw's Ninth Circuit Blog)
- Another Bite at the Graham Cracker: The Supreme Court's Surprise Revisiting of Juvenile Life Without Parole in Miller v. Alabama and Jackson v. Hobbs (Georgetown Law Journal)
- Juvenile Life Sentences Unconstitutional Without Parole (FindLaw's Decided)