As a general rule, state courts defer to U.S. Supreme Court rulings on interpretation of the Bill of Rights of the Constitution. However, the Court of Criminal Appeals of the State of Oklahoma took a different position in a case involving the sentencing of a juvenile offender. It what is becoming all-to-common, the Oklahoma court offered its own interpretation, situated on shaky ground at best. The Oklahoma court found a way to uphold another conviction by ruling that the Supreme Court prohibition on life sentences without parole for juveniles does not apply to multiple sentences that would effectively prevent a juvenile from ever leaving prison.
The Facts of the Oklahoma Case
The appeal filed with the Court of Criminal Appeals involved the conviction and sentencing of a 16-year-old juvenile offender. The juvenile was convicted of murder in the first degree, and two counts of shooting with intent to kill. The trial court imposed a sentence of life imprisonment on the murder offense and 15 years on each of the other two counts. The judge ordered that the sentences would run consecutively, so they were in effect stacked one on top of the other, creating a much longer sentence than if they were ran concurrently.
Attorneys for the juvenile argued the sentences amounted to cruel and unusual punishment in violation of the Eighth Amendment. Based on the argument, the court effectively denied the juvenile the possibility of parole by stacking all of the sentences on top of each other. In support of their argument, the Oklahoma juvenile’s attorneys relied on the 2010 United States Supreme Court ruling in Graham vs. Florida which held that the Eighth Amendment prohibited life sentences without parole for juveniles convicted of non-homicide offenses.
Although the original sentence did not specifically deny the juvenile the possibility of parole, the effect of the multiple sentences running consecutively would amount to deny the appellant the ability to ever leave prison. The Oklahoma attorneys argued that their client would not be eligible for parole on the homicide until he was 54 years old in 2042, but the consecutive sentences meant he would have to serve another 25.5 years before being eligible for parole on the two other offenses. Consequently, the juvenile would not be eligible for parole until the age of 79.
Juvenile Offenders are Not Guaranteed Parole
The Oklahoma Court pointed out that none of the crimes for which the juvenile was sentenced in Graham were homicides. The length of the Oklahoma sentence, as the court noted, was because the juvenile had participated in multiple offenses. According to the court, allowing offenders to avoid penalties for multiple violations of the law by arguing cruel and unusual punishment would amount to a “volume discount.” In one Judge’s opinion, granting relief would be tantamount to giving crimes away for free with no punishment or repercussions.
In its decision, the Oklahoma Court of Criminal Appeals addressed the question of whether it was compelled to follow cases in lower federal courts applying the Graham ruling to various factual situations. It declined to do so because it believed that each case and the sentence imposed must be analyzed on its own merits to determine if it complies with the Eight Amendment. Also on the Oklahoma Court’s side is the fact that the 10th Circuit (which holds intermediary federal jurisdiction for Oklahoma cases) has previously held that stacked, consecutive sentences are legally distinguishable from a single sentence of Life Without Parole (LWOP).
Although there is a split between federal circuit courts in their interpretation of this issue as it relates to the Graham decision, state courts have the authority, according to the Court of Criminal Appeals decision, to independently interpret decisions of the Supreme Court. It is not bound by interpretations offered by lower federal courts.
Two Judges Offer a Dissenting View of the Law
Two Judges joined in a dissenting opinion supporting the interpretation that states cannot impose sentences on juveniles amounting to permanent imprisonment. Under their analysis, consecutive sentences which make it likely a juvenile offender dies in prison are fundamentally equivalent to a life sentence without possibility of parole. Regardless, their position was not adopted by the other three Judges, resulting in a 3-2 decision.
The Importance of Skilled Representation
Movies and TV shows focus on criminal trials, but the decision from the Oklahoma Court of Criminal Appeals highlights how the manner in which a court imposes a sentence can affect a person’s life. Judges at all levels have a great deal of deference in how they sentence individual offenders. This decision further illustrates the important role played by skilled criminal defense attorneys at all phases of a criminal case. Whether at the trial court level or on appeal, zealous and creative advocacy is always imperative.
