Prentis Cordell Jackson v. State of Minnesota
883 N.W.2d 272, 2016 Minn. LEXIS 485 (2016)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
The U.S. Supreme Court's prohibition on mandatory life-without-release sentences for juvenile offenders applies retroactively. When a new sentencing hearing is not feasible due to the passage of time, the appropriate remedy is to sever the unconstitutional sentencing statute as-applied to the offender and revive the most recent, constitutional version of the statute to impose a new sentence.
Facts:
- On February 24, 2006, Prentis Cordell Jackson was 17 years old.
- Jackson and Alfred Lamar were members of the EMB gang.
- After a rival gang shot an EMB member, Jackson told Lamar that if he caught a rival he would harm them.
- Later that day, Jackson, Lamar, and two other gang members saw 15-year-old Michael Anthony Bluntson, Jr. walking on a sidewalk.
- Someone in the car suggested Jackson 'box' Bluntson, to which Jackson replied he was going to 'crush him.'
- Jackson exited the vehicle, approached Bluntson, and both assumed boxing stances.
- Instead of throwing a punch, Jackson pulled a gun from his waistband.
- After the gun misfired on the first attempt, Jackson pulled the trigger a second time, shooting Bluntson in the face.
Procedural Posture:
- Prentis Cordell Jackson was convicted of first-degree premeditated murder by a jury in a state district court.
- On November 21, 2006, the district court imposed the statutorily mandated sentence of life imprisonment without the possibility of release (LWOR).
- Jackson's conviction was affirmed by the Minnesota Supreme Court on direct appeal in 2008.
- In 2013, Jackson filed a petition for postconviction relief in the district court, challenging his sentence as unconstitutional under Miller v. Alabama.
- The postconviction court held an evidentiary hearing and subsequently denied Jackson's petition, concluding that Miller did not apply retroactively under existing state case law.
- Jackson (appellant) appealed the denial of his petition to the Minnesota Supreme Court, with the State as appellee.
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 Eighth Amendment, as interpreted by Miller v. Alabama and Montgomery v. Louisiana, require a court to vacate a mandatory life-without-release sentence imposed on a juvenile offender whose conviction was final before Miller, and impose a new sentence under a prior, constitutional version of the statute when a new individualized sentencing hearing is no longer feasible?
Opinions:
Majority - Anderson, J.
Yes. A mandatory life-without-release sentence imposed on a juvenile is unconstitutional under the Eighth Amendment, and this rule applies retroactively. When a resentencing hearing is not feasible, the court must vacate the sentence and apply the last constitutional version of the sentencing statute. The Supreme Court's decision in Montgomery v. Louisiana established that Miller v. Alabama's ban on mandatory life-without-release (LWOR) sentences for juveniles is a substantive rule that applies retroactively, thereby overruling prior Minnesota precedent. Jackson's mandatory LWOR sentence, imposed without any consideration of his youth, is therefore unconstitutional. The court determined that a new Miller hearing to assess Jackson's youthful characteristics from nearly a decade prior would not be fair or meaningful. As a remedy, the court adopts 'as-applied severance,' severing the unconstitutional mandatory LWOR statute only as it applies to Jackson and similarly situated juveniles, and revives the prior constitutional version of the statute (from 2004), which provides for life imprisonment with the possibility of release after 30 years.
Concurring - Stras, J.
Justice Stras concurred in the judgment only, agreeing that Jackson is entitled to be resentenced but for different reasons than the majority. Citing his dissent in a prior case, State v. Ali, he believes every juvenile offender facing a mandatory life sentence is entitled to relief. He advocates for partial severance of the statute, rather than as-applied severance and revival, as the proper remedy to resolve the constitutional defects in Minnesota's first-degree murder sentencing statutes for all juveniles, not just on a case-by-case basis.
Analysis:
This decision establishes a significant new remedy in Minnesota for handling cases where a sentencing law is found retroactively unconstitutional. By creating the 'as-applied severance and revival' doctrine, the court crafted a practical solution that avoids the evidentiary challenges of conducting sentencing hearings many years after the fact. This provides a clear and efficient pathway for resentencing a specific class of offenders—juveniles whose mandatory LWOR sentences were final before Miller v. Alabama—without invalidating the entire statute, which remains constitutional for adults. The case sets a powerful precedent for how state courts can judicially manage retroactive changes in substantive constitutional law when the legislature has not acted.
Unlock the full brief for Prentis Cordell Jackson v. State of Minnesota