Arrington v. State
113 So. 3d 20
Fla. Dist. Ct. App.2012Background
- This case arises from Arrington, a juvenile convicted of felony murder in Florida, sentenced to life without parole (LWOP).
- Arrington supplied a handgun used by a coconspirator in a robbery; he did not fire the weapon.
- The Florida statute (2006) mandatorily imposed LWOP for juvenile felony murder, with no discretion to tailor punishment.
- This court previously affirmed Arrington’s conviction and sentence, but withdrew the mandate to consider Graham v. Florida's implications.
- The court now analyzes whether the mandatory LWOP scheme can be unconstitutional as applied to juveniles under Graham’s proportionality framework.
- The court concludes the trial court must have case-specific discretion to determine if LWOP is proportionate given the juvenile’s circumstances and may impose lesser sentences.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Florida's mandatory LWOP for juvenile felony murder is constitutional as applied | Arrington maintains disproportionality risk under Graham. | Florida argues mandatory LWOP is permissible under current law. | Proceedings must consider proportionate sentencing; reverse and remand for discretion. |
| Whether proportionality review is required under Graham in this context | Graham mandates case-specific analysis for juveniles in felony murder. | Graham does not require universal noncategorical treatment of all such cases. | Court adopts proportionality framework to assess circumstances before imposing LWOP. |
| Whether the trial court should conduct a re-sentencing hearing with additional evidence | Discretionary review could lead to LWOP if shown proportionate. | Trial court should follow statutory framework and existing record. | Remand for re-sentencing with possible additional evidence and discretion. |
Key Cases Cited
- Graham v. Florida, 560 U.S. 48 (U.S. 2010) (held non-homicide juvenile LWOP violates Eighth Amendment unless individualized review)
- Harmelin v. Michigan, 501 U.S. 957 (U.S. 1991) (three-factor proportionality framework for noncapital sentences)
- Ewing v. California, 538 U.S. 11 (U.S. 2003) (narrow proportionality review applies to noncapital sentences)
- Lockett v. Ohio, 438 U.S. 586 (U.S. 1978) (requirement of individualized consideration in sentencing)
- Enmund v. Florida, 458 U.S. 782 (U.S. 1982) (focus on individual offender’s culpability in homicide-related crimes)
- Tison v. Arizona, 481 U.S. 137 (U.S. 1987) (individualized sentencing for accomplices in felony murder)
- Norris v. Morgan, 622 F.3d 1276 (9th Cir. 2010) (application of Harmelin-style proportionality to noncapital sentences)