Justices Seek to Avoid ‘Quagmire’ in Juvenile Felony Sentencing

(CN) – The Supreme Court on Monday said it will consider whether the life sentence without parole of a Virginia man who raped a 62-year-old woman when he was a teenager conforms to a subsequent ruling on the reasonable sentencing of juvenile offenders.

The per curiam opinion reverses a Fourth Circuit ruling that the man’s sentence conflicted with the high court’s ruling in Graham v. Florida.

Dennis LeBlanc raped his victim on July 6, 1999. He was 16 at the time. In 2003, a state trial court sentenced him to life in prison.

Prior to LeBlanc’s arrest and trial, Virginia did away with its longstanding parole framework for felony offenders and replaced it with the so-called “geriatric release” program, which allows older inmates to receive conditional release under some circumstances.

As a result, LeBlanc’s sentence amounted to life in prison without parole. However, seven years after he was sentenced, the Supreme Court decided Graham, which established that the Eighth Amendment prohibits juvenile offenders convicted of non-homicide offenses from being sentenced to life with-out parole.

With Graham, the justices held that while a “State is not required to guarantee eventual freedom to a juvenile offender convicted of a non-homicide crime,” it must “give defendants like Graham some meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation.”

The high court left it to the states to figure out how to comply with the Graham rule.

In light of Graham, LeBlanc asked the Virginia Beach Circuit Court to vacate his sentence, but the court declined, citing the Supreme Court of Virginia’s decision in Angel v. Commonwealth.

The Angel court held that Virginia’s geriatric release program satisfies Graham’s requirement of parole for juvenile offenders because it provides an avenue for the conditional release of long-serving inmates.

This satisfies Graham, the court held, because it provided “the meaningful opportunity to obtain release based on demonstrates maturity and rehabilitation required by the Eighth Amendment.”

The Virginia Supreme Court later denied LeBlanc’s request for a rehearing.

LeBlanc next took his case to the federal court in Richmond, where a magistrate judge recommended dismissing the case. The District Court disagreed and ultimately held that “there is no possibility that fair-minded jurists could disagree that the state court’s decision conflicts wit[h] the dictates of Graham.”

A divided Fourth Circuit agreed, holding the state trial court’s ruling was an unreasonable application of Graham.

In the panel majority’s view, Virginia’s geriatric release program did not provide a meaningful opportunity for juvenile non-homicide offenders to obtain release based on demonstrated maturity and rehabilitation.

But U.S. Circuit Judge Paul Niemeyer dissented, saying that his colleagues in the majority failed “to respect, in any meaningful way, the deference Congress requires federal courts to give state court decisions on post-conviction review.”

The Commonwealth of Virginia petitioned for certiorari, which the Supreme Court granted even as it reversed the Fourth Circuit ruling.

The justices noted that Monday’s ruling means only that the Virginia trial court’s ruling was not objectively unreasonable in light of current case law.

They found the Fourth Circuit erred because it failed to accord the state court’s decision the deference it was owed under the Antiterrorism and Effective Death Penalty Act of 1996, which mandated that a state prisoner is eligible for federal habeas relief if the underlying state court merits ruling was “contrary to, or involved an unreasonable application of, clearly established Federal law.

Graham did not decide that a geriatric release program like Virginia’s failed to satisfy the Eighth Amendment because that question was not presented,” Monday’s ruling says. “And it was not objectively unreasonable for the state court to conclude that, because the geriatric release program employed normal parole factors, it satisfied Graham’s requirement that juveniles convicted of a non-homicide crime have a meaningful opportunity to receive parole.

“The geriatric release program instructs Virginia’s Parole Board to consider factors like the ‘individual’s history … and the individual’s conduct … during incarceration,’ as well as the prisoner’s ‘inter-personal relationships with staff and inmates’ and ‘[c]hanges in attitude toward self and others,'” the opinion said.

But the court went on to say the LeBlanc case raised other issues.

“With regards to respondent, these include the contentions that the Parole Board’s substantial discretion to deny geriatric release deprives juvenile no-homicide offenders a meaningful opportunity to seek parole and that juveniles cannot seek geriatric release until they have spent at least four decades in prison,” the justices said, adding, “These arguments cannot be resolved on federal habeas review.

“Because this case arises ‘only in th[at] narrow context,’ the Court ‘express[es] no view on the merits of the underlying’ Eighth Amendment claim,” they said.

The justices concluded the Fourth Circuit ruling created the potential for significant discord in the Virginia sentencing process.

“Before today, Virginia courts were permitted to impose — and required to affirm — a sentence like respondent’s, while federal courts presented with the same fact pattern were required to grant habeas relief,” the justices said.

“Reversing the Court of Appeals’ decision in this case — rather than waiting until a more substantial split of authority develops — spares Virginia courts from having to confront this legal quagmire.”

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