Commonwealth v. Batts
125 A.3d 33
| Pa. Super. Ct. | 2015Background
- In 2006, 14-year-old Qu’eed Batts shot two teens in a gang-related attack; one victim died. Batts confessed and claimed duress/peer pressure from an older gang member.
- Batts was tried as an adult after a decertification hearing, convicted of first-degree murder, attempted murder, and aggravated assault; sentenced in 2007 to mandatory life without parole (LWOP).
- After the U.S. Supreme Court decided Miller v. Alabama (2012) (holding mandatory LWOP for juveniles unconstitutional), Pennsylvania Supreme Court vacated and remanded Batts for resentencing to consider youth-related factors (Batts II).
- At resentencing (May 2, 2014) the trial court considered extensive reports and expert testimony, weighed aggravating and mitigating (age-related) factors, and reimposed LWOP.
- Batts appealed, raising: (1) sufficiency of evidence to justify LWOP (arguing for heightened standard), (2) entitlement to capital-style procedural protections, and (3) that Batts II required imposition of a minimum term rather than LWOP.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency/standard to impose juvenile LWOP | Batts: appellate review should be de novo with Commonwealth proving "incorrigibility" beyond a reasonable doubt (heightened standard like capital cases). | Commonwealth: claim is discretionary sentencing challenge; no heightened standard mandated by Miller or Batts II. | Court: declined to create heightened standard; treated claim as discretionary-aspect of sentencing and found Batts’s Rule 2119(f) omission waived, so not reviewed on merits. |
| Procedural due process (capital-style protections) | Batts: juveniles facing LWOP deserve same procedural safeguards as adults facing death (jury sentence, higher burden, unanimity, automatic supreme court review). | Commonwealth: Miller requires individualized consideration of youth but does not mandate capital-style procedures; Batts II instructed only consideration of age-related factors. | Court: rejected Batts’s claim—no constitutional or statutory basis to import death-penalty procedures; trial court followed Batts II/Miller guidance. |
| Legality of LWOP after Batts II (requirement to impose minimum term) | Batts: Batts II required the trial court to impose a minimum term (i.e., life with parole possibility / definite minimum) rather than LWOP. | Commonwealth: Batts II and Miller do not categorically prohibit LWOP for juveniles if court gives individualized consideration; LWOP can be reimposed. | Court: LWOP was a legal sentence here because trial court considered required age-related factors; Batts II does not categorically bar juvenile LWOP. |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life without parole for juveniles violates the Eighth Amendment; individualized youth-based sentencing required)
- Graham v. Florida, 560 U.S. 48 (2010) (LWOP for juvenile non-homicide offenders violates Eighth Amendment)
- Roper v. Simmons, 543 U.S. 551 (2005) (death penalty unconstitutional for crimes committed under age 18)
- Commonwealth v. Batts, 66 A.3d 286 (Pa. 2013) (Batts II) (Pennsylvania Supreme Court remanded for resentencing and required consideration of age-related factors under Miller)
- Commonwealth v. Knox, 50 A.3d 732 (Pa. Super. 2012) (identifies age-related factors trial courts should consider when deciding juvenile LWOP)