Brown v. Hobbs
2014 Ark. 267
Ark.2014Background
- Brown pleaded guilty to first-degree murder in 1982 and was sentenced to life imprisonment.
- In 2013 Brown petitioned for a writ of habeas corpus claiming Miller v. Alabama and Jackson require consideration of youth mitigating factors, making the life sentence illegal.
- The State argued Miller and Jackson were not applicable to Brown's case.
- The circuit court dismissed Brown's habeas petition on October 1, 2013.
- Brown appeals, contending his discretionary life sentence should have factored in his youth; the State argues Miller is inapplicable to nonmandatory life.
- The Arkansas Supreme Court affirmed, holding Brown's sentence was discretionary and Miller/Murry do not render it illegal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miller/Jackson require youth consideration in Brown's sentence. | Brown asserts Miller and Jackson require youth consideration in all placements. | State contends Miller does not apply to nonmandatory life; Murry controls. | Miller inapplicable; Brown's discretionary sentence affirmed. |
Key Cases Cited
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (barred mandatory life without parole for juveniles; require consideration of youth)
- Jackson v. Norris, 2013 Ark. 175 (Ark. Supreme Court, 2013) (remanded to consider Miller evidence where sentencing was mandatory or lacked youth factors)
- Murry v. Hobbs, 2013 Ark. 64 (Ark. Supreme Court, 2013) (Miller applicable only to mandatory life; not extend to discretionary life sentences)
- Britt v. State, 2014 Ark. 134 (Ark. Supreme Court, 2014) (reaffirmed Murry; Miller inapplicable to nonmandatory life sentences)
- Smith v. Hobbs, 2014 Ark. 204 (Ark. Supreme Court, 2014) (explained Miller in context of prior Arkansas rulings; Miller not applicable to nonmandatory life)