Commonwealth v. Battles
169 A.3d 1086
| Pa. Super. Ct. | 2017Background
- In 1977 Ricky Lynn Battles (age 16) pled guilty to criminal homicide in the killing of his uncle; a three-judge panel found him guilty of first-degree murder and he was sentenced to life in 1978.
- Battles pursued post-conviction challenges and an untimely PCRA petition in 2012 invoking Miller v. Alabama; the petition was denied and affirmed based on Cunningham.
- After Montgomery v. Louisiana (which made Miller retroactive), Battles filed a counseled PCRA petition in 2016 and was granted resentencing.
- At resentencing (Dec. 9, 2016) the trial court imposed a sentence of 35 years to life with credit; Battles challenged the legality and discretionary aspects of the life maximum.
- The Superior Court affirmed: it held (1) a life maximum is legal for pre‑Miller juvenile first‑degree murderers under Commonwealth v. Batts, and (2) the court could not have abused discretion when imposing a mandatory life maximum.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Legality of imposing a life maximum on a juvenile convicted of first‑degree murder | Battles: a life maximum is unconstitutional under Miller and Batts I; Miller’s youth‑based reasoning requires individualized maximums | Commonwealth / Trial Ct: Batts I permits and in some cases mandates a life maximum for pre‑Miller juvenile first‑degree murderers; Miller forbids only mandatory LWOP without parole | Court: Life maximum is legal under Batts I; no relief on legality claim |
| Discretionary‑aspect challenge to life maximum (abuse of discretion/excessive) | Battles: imposition of life maximum was excessive and violated sentencing norms for juveniles | Commonwealth / Trial Ct: The maximum life term is mandatory under §1102(a) for pre‑Miller sentences; therefore no discretionary error | Court: No substantial question raised; even on merits no relief because court had no discretion to avoid the mandatory life maximum |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (holding mandatory life without parole for juvenile homicide offenders unconstitutional)
- Montgomery v. Louisiana, 577 U.S. 190 (2016) (Miller announced a new substantive rule that is retroactive)
- Commonwealth v. Batts, 66 A.3d 286 (Pa. 2013) (pre‑Miller juvenile first‑degree murderers can receive mandatory life maximums with judicially set minimums on resentencing)
- Commonwealth v. Cunningham, 81 A.3d 1 (Pa. 2013) (addressed retroactivity before being abrogated by Montgomery)
- Commonwealth v. Cardwell, 105 A.3d 748 (Pa. Super. 2014) (standard of review for legality of sentence)
- Commonwealth v. Griffin, 65 A.3d 932 (Pa. Super. 2013) (four‑part test for preserving and presenting discretionary sentencing challenges)
- Commonwealth v. Battles, 105 A.3d 41 (Pa. Super. 2014) (prior Superior Court decision denying Battles relief under Cunningham)