Beach v. State, 2015 MT 118

Background

Barry Allan Beach committed homicide at age 17 (1979), was convicted by a jury in 1984, and received a 100‑year sentence without parole (deemed by the court to be the functional equivalent of LWOP).
Beach’s conviction and sentence became final in 1985 after direct review; he later filed a habeas petition arguing his sentence is unconstitutional under Miller v. Alabama (2012).
Miller requires that before imposing life without parole (LWOP) on a juvenile homicide offender a sentencer must consider youth‑related characteristics; Miller also invalidated mandatory LWOP schemes for juveniles.
The dispositive question: whether Miller’s sentencing‑consideration rule is retroactive on collateral review in Montana.
The Montana Supreme Court applied the federal Teague retroactivity framework (which generally bars new rules on collateral review except substantive rules or watershed procedural rules) and concluded Miller’s consideration rule is new but not retroactive; Beach’s petition was denied.

Issues

Issue	Plaintiff's Argument (Beach)	Defendant's Argument (State)	Held
Does Miller create a new rule that applies retroactively on collateral review?	Miller requires sentencers to consider youth before imposing LWOP; that rule should apply retroactively.	Miller’s requirement is procedural (or dicta regarding considerations) and thus non‑retroactive under Teague.	Miller’s sentencing‑consideration rule is a new rule; it is not retroactive on collateral review.
If Miller is new, is it substantive or a watershed procedural rule (exceptions to Teague)?	Miller’s rule effectively prohibits LWOP for juveniles unless youth‑factors are considered—functionally substantive.	Miller merely prescribes a sentencing process; it does not categorically bar LWOP and so is procedural and not watershed.	Miller’s rule is procedural and not a watershed rule; it is not substantive under Schriro and related precedent.
Did Montana have a mandatory LWOP scheme or a presumption that would make Miller more obviously retroactive?	Miller’s reasoning (youth = diminished culpability) applies regardless; fairness demands retroactive application.	Montana’s sentencing scheme was discretionary and already required individualized consideration; Miller’s mandatory‑scheme holding doesn’t apply.	Montana’s discretionary scheme and absence of a mandatory LWOP presumption weigh against treating Miller as substantive; no retroactivity.
Procedural default / jurisdictional: is habeas an appropriate vehicle despite statutory bars?	Miller was decided after appeal deadlines; Lott permits habeas where a sentence is facially invalid under a new rule.	State argued procedural bar.	Court found Beach’s claim sufficiently raised facial invalidity to avoid statutory bar and proceeded to retroactivity analysis, but denied relief on retroactivity grounds.

Key Cases Cited

Miller v. Alabama, 567 U.S. 460 (2012) (requires sentencers to consider juvenile status before imposing LWOP; invalidates mandatory juvenile LWOP schemes)
Graham v. Florida, 560 U.S. 48 (2010) (categorically prohibits LWOP for juveniles convicted of non‑homicide offenses)
Roper v. Simmons, 543 U.S. 551 (2005) (categorically prohibits death penalty for juvenile offenders)
Teague v. Lane, 489 U.S. 288 (1989) (new rules generally not retroactive on collateral review except substantive or watershed procedural rules)
Schriro v. Summerlin, 542 U.S. 348 (2004) (clarifies substantive vs. procedural sentencing rules for retroactivity)
Penry v. Lynaugh, 492 U.S. 302 (1989) (substantive sentencing rules discussed in retroactivity context)
Griffith v. Kentucky, 479 U.S. 314 (1987) (new constitutional rules apply on direct review)
Lockett v. Ohio, 438 U.S. 586 (1978) (individualized sentencing considerations required in capital cases)
Woodson v. North Carolina, 428 U.S. 280 (1976) (individualized sentencing required in death penalty cases)
Apprendi v. New Jersey, 530 U.S. 466 (2000) (facts that increase maximum punishment must be found by a jury)