Bramlett v. Hobbs
463 S.W.3d 283
Ark.2015Background
- In 1979 Steven Wayne Bramlett, age 17 at the time, pled guilty to attempted capital murder and received a life sentence.
- In 2011 Bramlett filed a pro se declaratory-relief action arguing, under Graham v. Florida, that his life sentence for a juvenile nonhomicide offense violates the Eighth Amendment and sought resentencing to a term of years.
- The State moved to dismiss and for summary judgment; the circuit court granted summary judgment for the State, concluding attempted capital murder is a homicide offense under Graham because Bramlett intended to kill.
- Bramlett appealed; the Arkansas Supreme Court initially ordered supplementation of the record, which was supplied, and the appeal proceeded on the sole issue whether Graham entitles Bramlett to relief.
- The Arkansas Supreme Court reviewed Arkansas statutory and case-law definitions of homicide (which require death), other states’ treatments, and Graham’s categorical approach.
- The court held that attempted capital murder is not a "homicide" offense for purposes of Graham, reversed the circuit court’s summary-judgment dismissal, and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether attempted capital murder counts as a "homicide" under Graham (thus permitting life without parole for a juvenile) | Bramlett: homicide requires actual death; attempted capital murder is a nonhomicide, so Graham forbids life-without-parole for juveniles convicted of it | State: Graham’s language treats those who intend to kill as within the more serious class; Bramlett intended to kill, so attempted capital murder is effectively a homicide for Graham | Court: Attempted capital murder is not a homicide for purposes of Graham; Graham’s bar on life-without-parole for juvenile nonhomicide offenders applies; reverse and remand |
Key Cases Cited
- Graham v. Florida, 560 U.S. 48 (2010) (Eighth Amendment forbids life without parole for juvenile nonhomicide offenders; adopts categorical line between homicide and nonhomicide)
- Kennedy v. Louisiana, 554 U.S. 407 (2008) (distinguishes homicide from other serious crimes in proportionality analysis)
- Enmund v. Florida, 458 U.S. 782 (1982) (capital punishment proportionality principles)
- Tison v. Arizona, 481 U.S. 137 (1987) (liability and culpability standards for capital punishment)
- Coker v. Georgia, 433 U.S. 584 (1977) (proportionality and severity comparisons among crimes)
- Lipsey v. Giles, 439 S.W.3d 13 (Ark. 2014) (summary-judgment standard and when reasonable minds could differ on inferences)
- Manuel v. State, 48 So.3d 94 (Fla. Dist. Ct. App. 2010) (held attempted murder is a nonhomicide for Graham purposes and life-without-parole for juvenile invalid)
- Ware v. State, 348 Ark. 181 (2002) (Arkansas discussion of corpus delicti in homicide: proof that death occurred and was caused by another)
- Edmonds v. State, 34 Ark. 720 (1879) (early Arkansas statement that corpus delicti for homicide requires proof of death)