Aiken v. Byars
765 S.E.2d 572, 2014 S.C. LEXIS 494, 410 S.C. 534 (2014)
Rule of Law:
The U.S. Supreme Court's decision in Miller v. Alabama applies retroactively to cases on collateral review and requires that sentencing courts affirmatively consider specific youth-related mitigating factors before imposing life without parole on a juvenile, regardless of whether the state's sentencing scheme is mandatory or discretionary.
Facts:
- Fifteen individuals committed homicide offenses while they were under the age of eighteen.
- Following their arrests, some of the individuals pleaded guilty while others were convicted by juries.
- The trial courts sentenced each individual to life imprisonment without the possibility of parole.
- At the time of these sentences, South Carolina law allowed, but did not strictly mandate, life without parole for these crimes; however, the sentencing procedures did not distinguish between adult and juvenile offenders.
- During the original sentencing hearings, defense counsel generally mentioned the defendants' ages merely as chronological facts or in vague pleas for mercy.
- The sentencing judges imposed the life terms without conducting individualized inquiries into the specific characteristics of youth, such as immaturity or susceptibility to peer pressure.
- The inmates remained incarcerated serving life terms while the legal landscape regarding juvenile sentencing evolved at the federal level.
Procedural Posture:
- The fifteen petitioners were convicted of homicide and sentenced to life without parole in South Carolina Courts of General Sessions (trial courts).
- Thirteen of the petitioners' cases became final following direct appeals to the South Carolina Court of Appeals and/or Supreme Court.
- The U.S. Supreme Court issued its decision in Miller v. Alabama.
- The petitioners filed a petition for a writ of certiorari in the South Carolina Supreme Court's original jurisdiction against the Director of Corrections and the Attorney General.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the ruling in Miller v. Alabama, which forbids mandatory life without parole for juveniles, apply retroactively to finalized cases and extend to juvenile offenders sentenced under a statute that permits but does not mandate such sentences?
Opinions:
Majority - Justice Hearn
Yes, Miller applies retroactively and extends to discretionary sentencing schemes. The Court reasoned that Miller established a new substantive rule of constitutional law under the Teague standard because it prohibits a specific category of punishment (life without parole) for a specific class of defendants (juveniles) absent individualized consideration. The Court rejected the argument that Miller applies only to mandatory schemes, holding that the Eighth Amendment requires an affirmative exploration of the specific characteristics of youth. Because the original sentencing courts failed to explicitly weigh factors like immaturity and potential for rehabilitation, the sentences violated the Constitution. The Court ordered resentencing for all petitioners.
Concurring - Justice Pleicones
Yes, the petitioners are entitled to resentencing. Justice Pleicones agreed with the result but diverged on the reasoning. He agreed with the dissent that under current federal Eighth Amendment jurisprudence, Miller technically addressed only mandatory schemes. However, he argued that the relief should be granted based on the South Carolina Constitution (Article I, § 15), reaching the same outcome as the majority through state constitutional protections.
Dissenting - Chief Justice Toal
No, Miller does not apply to these cases because South Carolina's sentencing scheme was discretionary, not mandatory. The dissent argued that Miller was explicitly limited to laws that precluded sentencers from considering age, whereas South Carolina judges always had the discretion to consider mitigation. Chief Justice Toal contended that applying Miller retroactively to discretionary sentences creates a new rule not supported by Supreme Court precedent. The dissent also argued that the Court should have reviewed the original transcripts for abuse of discretion rather than granting a blanket resentencing.
Analysis:
This case is significant because it expands the protections of Miller v. Alabama beyond the narrow scope of 'mandatory' sentencing statutes. The South Carolina Supreme Court recognized that a statute might be discretionary on its face but still result in unconstitutional applications if the sentencing judge does not affirmatively weigh the specific factors of youth. By making this rule retroactive, the Court ensured that inmates whose convictions were long final could still benefit from evolving standards of decency. This decision aligns South Carolina with jurisdictions that view the 'individualized sentencing' requirement as a substantive right for juveniles facing the harshest penalties.
