Commonwealth v. Batts, Q., Aplt.
2017 Pa. LEXIS 1477
| Pa. | 2017Background
- Qu’eed Batts, convicted of first-degree murder for a killing he committed at age 14, was originally sentenced to mandatory life without parole; his case returned to the Pennsylvania Supreme Court after resentencing to life without parole.
- Batts’ youth, traumatic foster‑care history, gang involvement, and expert psychiatric/psychological testimony (for both sides) were central at resentencing; the sentencing court found both aggravating facts (premeditation, gang promotion, danger to public) and mitigating signs of potential for rehabilitation.
- The trial court resentenced Batts to life without parole; the Superior Court affirmed (on procedural grounds), and this appeal presented whether that sentence is legal under Miller v. Alabama and Montgomery v. Louisiana.
- The Pennsylvania Supreme Court in Batts I (2013) previously held that for juveniles convicted pre‑Miller, courts could sever parole prohibition so juveniles could be resentenced with life as the maximum and a minimum term set by the trial court (making parole possible).
- The Court here evaluates: (1) whether Batts’ life‑without‑parole sentence is unconstitutional under Miller/Montgomery; (2) whether procedural protections (presumption, burden, expert evidence, jury) are required; and (3) the validity and scope of Batts I’s severance/remedy.
Issues
| Issue | Plaintiff's Argument (Batts) | Defendant's Argument (Commonwealth/DAA) | Held |
|---|---|---|---|
| Legality of LWOP for juvenile (as applied) | Batts argued Miller/Montgomery make his LWOP illegal because sentencing court failed to find he is irreparably incorrigible; appellate review should be de novo. | Commonwealth argued sentencing court complied with required balancing and appellate review should be abuse‑of‑discretion. | Court held Miller/Montgomery require a sentencing court to find permanent incorrigibility before LWOP; legal conclusion reviewed de novo while factual findings get deference. Batts’ LWOP was illegal and reversed. |
| Burden and presumption at juvenile LWOP sentencing | Batts urged a presumption against LWOP for juveniles and that Commonwealth must prove eligibility beyond a reasonable doubt with expert evidence. | Commonwealth/DAA opposed imposing new procedural rules, urged judge‑only factfinding and ordinary standards. | Court adopted a rebuttable presumption against juvenile LWOP and assigned the Commonwealth the burden to prove permanent incorrigibility beyond a reasonable doubt; expert testimony not categorically required. |
| Need for jury determination / Alleyne/Apprendi concerns | Batts argued juvenile LWOP requires jury finding (like capital cases) and automatic Supreme Court review. | Commonwealth and DAA argued Alleyne/Apprendi do not apply because permanent incorrigibility is not an element of the offense and Supreme Court precedent contemplates judge sentencing. | Court held no constitutional right to jury determination or automatic Supreme Court review; judge may make the Miller/Montgomery assessment. |
| Validity of Batts I remedy (severance of parole prohibition) | Batts/PACDL argued Batts I improperly severed statutes leaving no lawful penalty and thus pre‑Miller juveniles should be resentenced as lesser offenses. | Commonwealth defended Batts I severance as permissible and consistent with legislative intent and precedent (and Legislature’s inaction supports it). | Court reaffirmed Batts I: severance of the parole prohibition is permissible; juveniles may be resentenced to life with parole eligibility and minimums should be guided by §1102.1. |
Key Cases Cited
- Roper v. Simmons, 543 U.S. 551 (2005) (juveniles are categorically less culpable; death penalty for juveniles is unconstitutional)
- Graham v. Florida, 560 U.S. 48 (2010) (life without parole for juvenile non‑homicide offenders unconstitutional; need for meaningful opportunity for release)
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory LWOP for juveniles unconstitutional; sentencing must be individualized and LWOP "uncommon")
- Montgomery v. Louisiana, 136 S. Ct. 718 (2016) (Miller announced a substantive retroactive rule; LWOP only for the "rarest" juveniles whose crimes reflect irretrievable depravity)
- Commonwealth v. Batts (Batts I), 620 Pa. 115, 66 A.3d 286 (Pa. 2013) (severed parole prohibition to permit resentencing juvenile lifers with parole eligibility)
- Apprendi v. New Jersey, 530 U.S. 466 (2000) (facts increasing penalty beyond statutory maximum must be submitted to a jury)
- Alleyne v. United States, 570 U.S. 99 (2013) (any fact that increases mandatory minimum is an element for jury determination)