United States v. Briones

The en banc court vacated and remanded defendant's sentence of life without the possibility of parole (LWOP) for his role in a robbery that resulted in murder. Defendant was 17 years old at the time. The Supreme Court later held that mandatory LWOP sentences for juvenile offenders violated the Eighth Amendment's prohibition on cruel and unusual punishment in Miller v. Alabama, 567 U.S. 460, 465 (2012). The Ninth Circuit held that the district court's analysis during resentencing was inconsistent with the constitutional principles the Supreme Court delineated in Miller and subsequent case law. In this case, based on the district court's articulated reasoning at defendant's resentencing, the panel could not tell whether the district court appropriately considered the relevant evidence of defendant's youth or the evidence of his post-incarceration efforts at rehabilitation. Furthermore, defendant provided evidence related to a number of the Miller factors at the resentencing hearing, including his abusive upbringing, his extensive exposure to drugs and alcohol as a child, his difficulty in high school because of his Native American traditions, and his father's inexplicable insistence that he reject the government's favorable plea offer. Most significantly, defendant offered abundant evidence on the critical issue that he was not irreparably corrupt or irredeemable because he had done what he could to improve himself within the confines of incarceration. View "United States v. Briones" on Justia Law