Commonwealth v. Machicote, A., Aplt.
206 A.3d 1110
Pa.2019Background
- In 2003, then-17-year-old Appellant and a co-resident assaulted and bound a night supervisor at a youth facility; the supervisor later died. Appellant pled guilty to second-degree murder in 2004.
- Appellant was originally sentenced in 2005 to life without parole (LWOP); he did not appeal that sentence.
- After Miller v. Alabama (2012) and related Pennsylvania decisions, Appellant sought resentencing under Miller/Montgomery; the PCRA court vacated his LWOP sentence and resentenced him in 2014 to life with parole (recommendation no parole until age 58).
- The Commonwealth successfully appealed, and the Superior Court ordered imposition of the original LWOP sentence in 2015. That sentence was later vacated; at a 2016 resentencing the trial court imposed 30 years to life (parolable).
- Appellant challenged that resentencing on grounds the trial court failed to place Miller-factor findings on the record when he faced a possible LWOP sentence; the Superior Court treated that challenge as moot because LWOP was not imposed. The Pennsylvania Supreme Court granted review.
Issues
| Issue | Plaintiff's Argument (Machicote) | Defendant's Argument (Commonwealth) | Held |
|---|---|---|---|
| Whether sentencing a juvenile who faced potential LWOP requires on-the-record consideration of Miller factors even if LWOP is not ultimately imposed | Trial court must consider and state Miller factors on record whenever juvenile faces potential LWOP; failure renders sentence illegal | Miller/§1102.1 apply only to juveniles convicted of first-degree murder; since Appellant was convicted of second-degree murder and was parolable, §1102.1(d) did not require on-the-record Miller findings | Court held trial courts must consider Miller factors on the record whenever a juvenile faces a potential LWOP sentence, regardless of ultimate sentence; failure makes sentence illegal and requires resentencing |
| Whether Appellant was exposed to potential LWOP at sentencing | Appellant: because he was convicted prior to Miller and Commonwealth sought LWOP at resentencing, he was exposed to potential LWOP and Miller applied | Commonwealth: §1102.1 confines LWOP exposure and Miller-factor obligations to first-degree convictions after June 24, 2012 | Court agreed with Appellant: because conviction predated Miller and Commonwealth sought LWOP, Appellant was exposed to potential LWOP and Miller-factor consideration was required |
| Whether the Superior Court’s mootness disposition was correct | Appellant: Mootness incorrect—procedural Miller protections cannot be nullified by the fact LWOP was not imposed; record must show individualized consideration | Commonwealth: Issue is moot if LWOP not imposed; alternatively, trial court effectively addressed Miller factors via prior comments | Court reversed Superior Court: the mootness holding was error; Miller-factor consideration on the record is required even where LWOP is not imposed |
| Scope of relief for failure to consider Miller factors | Appellant: Failure renders sentence illegal and mandates vacatur and remand for resentencing with on-the-record findings | Commonwealth: Even if required, trial court sufficiently considered Miller factors across hearings; sentence was lawful | Court held sentence illegal due to absence of on-the-record Miller-factor findings and vacated sentence; remanded for resentencing with required on-the-record consideration |
Key Cases Cited
- Roper v. Simmons, 543 U.S. 551 (U.S. 2005) (Eighth Amendment bars death penalty for offenders under 18)
- Graham v. Florida, 560 U.S. 48 (U.S. 2010) (Eighth Amendment bars LWOP for juvenile nonhomicide offenders)
- Miller v. Alabama, 567 U.S. 460 (U.S. 2012) (Mandatory LWOP for juveniles violates Eighth Amendment; sentencer must consider youth-related factors)
- Montgomery v. Louisiana, 136 S. Ct. 718 (U.S. 2016) (Miller announces a substantive rule that applies retroactively; juveniles must be given opportunity to show they are not irreparably corrupted)
- Commonwealth v. Batts, 620 Pa. 115, 66 A.3d 286 (Pa. 2013) (Batts I) (Pennsylvania's response to Miller; remedial framework for resentencing)
- Commonwealth v. Batts, 640 Pa. 401, 163 A.3d 410 (Pa. 2017) (Batts II) (clarified presumption against juvenile LWOP and required consideration of Miller factors; Commonwealth bears burden to prove permanent incorrigibility)