Eighth Amendment

SCOTUS to Consider Limits on Life Sentences for Juveniles

The Supreme Court announced that it would take up the case in Jones v. Mississippi, No. 18-1259, where the defendant stabbed his grandfather to death when he was 15 years old. The Court will consider under what circumstances courts can sentence juveniles to life without parole. The defendant was sentenced to life without parole under a mandatory sentencing law.

Click here to read the article from the New York Times.

McKinney v. Arizona (U.S. Supreme Court, February 2020)

The Supreme Court held that allowing a state appellate court to reweigh the aggravating and mitigating factors in a capital case under Clemons v. Mississippi is a permissible remedy after a finding on collateral review that the sentence court failed to consider mitigating factors in violation of Eddings v. Oklahoma.

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Willie B. Smith, III v. Commissioner (11th Cir. May 2019)

The Court affirmed the district court’s denial of the defendant’s habeas petition under § 2254. The defendant failed to show that the state court’s denial of Atkins claim of ineligibility for the death penalty due to intellectual disability or denial of his Batson claim were contrary to clearly established law or constituted an unreasonable determination of the facts. The Court also held that the requirement in Moore v. Texas that state courts consider prevailing medical standards in adjudicating Atkins claims was not retroactive under Teague.

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United States v. Tremane Carthen, et al. (11th Cir. October 2018)

The Court affirmed the convictions of two defendants who were sentenced under § 924(c), holding that the district court did not err in admitting hearsay testimony from a co-conspirator or in excluding specific instances of the co-conspirators prior lies to impeach him, and that the mandatory sentencing scheme in § 924(c) was constitutional.

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