STATE v. ACKEEM RILEY, SC 19109

Judicial District of Hartford

 Criminal; Juveniles; Whether Juvenile Defendant’s Sentence of 100 Years of Incarceration Violated Eighth Amendment’s Prohibition Against Cruel and Unusual Punishment.  The defendant was accused of committing multiple crimes when he was seventeen years of age.  He was ultimately convicted of, among other things, murder, attempted murder, and assault in the first degree.  The trial court subsequently sentenced him to 100 years of incarceration, which was the functional equivalent of a life sentence without the possibility of release.  On appeal, the defendant claimed that he was entitled to a resentencing procedure under Miller v. Alabama, 132 S. Ct. 2455 (2012), which held that the eighth amendment’s prohibition against cruel and unusual punishment forbids a sentencing scheme that mandates life in prison without the possibility of parole for juvenile offenders.  The defendant maintained that although the sentence he received was not mandatory, it contravened Miller because the court failed to consider his youth in imposing the sentence and failed to specifically articulate why such a severe sentence was appropriate despite his age.  The Appellate Court (140 Conn. App. 1) disagreed, determining that, while Miller requires that a juvenile defendant be given the opportunity to present mitigating evidence where life without parole is a possible penalty, it did not dictate any particular sentencing procedure that courts must follow.  The court further concluded that the sentencing procedure at issue here did not contravene Miller because the trial court was not obligated to sentence the defendant to life without the possibility of release and was instead provided with a great deal of discretion in determining an appropriate sentence pursuant to Connecticut’s sentencing statutes and rules of practice.  The court also emphasized that, although Connecticut’s sentencing procedures do not mandate that courts specifically consider a juvenile’s deficiencies, the trial court in the present matter addressed many of the mitigating factors identified in Miller, such as the defendant’s age, family, and upbringing, but simply determined that those factors did not justify a reduced sentence in light of the severity of the defendant’s crimes.  The court also noted that the defendant had the opportunity to present mitigating evidence related to his age and upbringing but that he declined to fully avail himself of that opportunity.  Accordingly, the court held that the defendant’s sentence was constitutional.  In this appeal, the Supreme Court will determine whether the Appellate Court correctly concluded that the juvenile defendant’s total sentence of 100 years imprisonment was properly imposed under the eighth amendment to the United States constitution as interpreted by Miller and by Graham v. Florida, 130 S. Ct. 2022 (2010).