Britt v. State
2014 Ark. 134
Ark.2014Background
- Antonio Britt was convicted in 1996 of first-degree murder, attempted first-degree murder, two counts of aggravated robbery (merged), and two counts of kidnapping for offenses in 1995.
- On retrial in 2000, Britt was convicted of first-degree murder, attempted first-degree murder, and two kidnapping counts, receiving multiple life terms plus a 360-month sentence for attempted murder.
- On May 23, 2013 Britt filed a pro se habeas corpus petition in Lee County challenging his life sentence as a juvenile offender.
- The Lee County Circuit Court dismissed the habeas petition for failure to conform to pleading rules.
- Britt appealed pro se; the Supreme Court of Arkansas dismissed the appeal as moot, holding the petition lacked merit and appointment of counsel/extension motions were moot.
- Key reasoning relied on Miller v. Alabama and related jurisprudence showing the sentence was not mandatory and that Britt could not prevail on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Britt's habeas appeal merits further review | Britt contends life sentence for juvenile murder violates Miller | State argues petition lacks merit and is moot | Appeal dismissed as moot; no merit to proceed |
| Whether Miller-based challenge renders life sentence illegal | Miller requires consideration of youth and prohibits mandatory life | Under Arkansas law, life was not mandatory for Britt; sentencing range allowed | Not illegal under Miller; dismissal affirmed |
| Whether petition complied with statutory requirements for habeas relief | Petition quotes authorities; alleges illegal detention | Petition failed to meet probable-cause and substance requirements | Denied; petition failed to show probable cause or proper basis for writ |
| Whether Graham and related nonhomicide arguments were properly raised | Graham bar on life without parole for juvenile nonhomicide offenders | No Graham basis raised below; not considered on appeal | Not considered; arguments not raised below |
| Whether appellate counsel/extension requests should be granted | Requests for counsel and time extension are necessary for appeal | Moot since appeal lacks merit | Moot; denied as unnecessary |
Key Cases Cited
- Miller v. Alabama, 132 S. Ct. 2455 (U.S. 2012) (Eighth Amendment considers youths when imposing lengthy sentences)
- Murry v. Hobbs, 2013 Ark. 64 (Ark. 2013) (juvenile-life sentence not mandatory under Miller when range of punishments exists)
- Glaze v. State, 2013 Ark. 458 (Ark. 2013) (per curiam; habeas relief standard applied)
- Culbertson v. State, 2012 Ark. 112 (Ark. 2012) (denial of habeas relief reviewed per curiam)
- Justus v. Hobbs, 2013 Ark. 149 (Ark. 2013) (per curiam; standard for appellate review in habeas cases)
- Darrough v. State, 2013 Ark. 28 (Ark. 2013) (requirement of probable cause; habeas petition standards)