Commonwealth v. MacHicote
172 A.3d 595
| Pa. Super. Ct. | 2017Background
- In 2003, 17‑year‑old Anthony Machicote and an accomplice fatally suffocated a night supervisor during an escape from a juvenile facility; Machicote pled guilty to second‑degree murder in 2004 and received life imprisonment.
- Machicote pursued multiple PCRA petitions and resentencings after Miller v. Alabama and related Pennsylvania decisions addressing juvenile LWOP sentences.
- In 2014 he was resentenced to life with parole eligibility (recommendation to defer parole until age 58); that resentencing was vacated on appeal and he was returned to life without parole in 2015.
- After Montgomery and related developments, the PCRA court vacated the 2015 sentence and on August 19, 2016 resentenced Machicote to 30 years to life.
- Machicote appealed, arguing (1) the term‑of‑years plus life maximum was statutorily unauthorized for pre‑2012 juvenile second‑degree murderers, (2) the court failed to adequately consider youth/Miller factors, and (3) the court abused discretion by granting expert funds but denying a continuance to hire a mitigation expert.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Legality of 30 years–to–life sentence for pre‑2012 juvenile second‑degree murder | Machicote: No legislatively authorized alternative to LWOP exists for pre‑June 25, 2012 convictions; therefore only conviction reduction or third‑degree murder applies | Commonwealth/PCRA court: Batts framework permits imposition of a minimum term‑of‑years with life maximum, exposing defendant to parole eligibility | Affirmed: 30 years–to–life lawful under Batts line; court bound by Supreme Court’s interpretation allowing term‑of‑years min + life max |
| Failure to consider Miller youth‑related factors at resentencing | Machicote: Court did not fully evaluate youth/mitigation (Knox/Miller factors) before resentencing | PCRA court/Commonwealth: Court considered PSI, prior sentencing findings, and concluded LWOP inappropriate so Miller individualized inquiry was unnecessary | No relief: claim does not raise substantial question; even on merits court did not abuse discretion and considered relevant information |
| Denial of continuance after granting funds for mitigation expert | Machicote: Granting funds but denying continuance effectively precluded meaningful expert mitigation evidence | PCRA court: Funding discretionary; expert testimony not always constitutionally required; here LWOP was deemed inappropriate, rendering issue moot | Denied: Batts/Batts II allow court discretion on expert necessity; contradiction noted but no reversible error since LWOP not imposed |
| Applicability of Miller/Montgomery burdens and proof at resentencing | Machicote: Implied argument that Commonwealth must meet certain standards and defendant needed resources to contest permanent incorrigibility | Commonwealth/PCRA court: Under Batts II, presumption against juvenile LWOP and Commonwealth must prove permanent incorrigibility beyond reasonable doubt; expert evidence admissible but not always required | Decision applied Batts framework; because court found LWOP inappropriate, burden/practical consequences did not alter result |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory LWOP for juveniles violates Eighth Amendment)
- Montgomery v. Louisiana, 136 S. Ct. 718 (2016) (Miller announced a substantive rule requiring retroactive relief for juvenile LWOP)
- Commonwealth v. Batts, 66 A.3d 286 (Pa. 2013) (Batts I: guidance on resentencing juvenile lifers and permitting term‑of‑years minima with life maximum)
- Commonwealth v. Cunningham, 81 A.3d 1 (Pa. 2013) (addressed trial court authority on resentencing post‑Miller)
- Commonwealth v. Konias, 136 A.3d 1014 (Pa. Super. 2016) (discretionary nature of providing public funds for defense experts)