Cyntoia Brown v. Carolyn Jordan
563 S.W.3d 196
Tenn.2018Background
- In 2004, then‑16‑year‑old Cyntoia Brown was tried as an adult, convicted of first‑degree murder and sentenced to life imprisonment; the trial court noted she "must serve at least fifty‑one (51) calendar years before she is eligible for release."
- Brown challenged her sentence in state post‑conviction proceedings and later filed a federal habeas petition invoking Miller v. Alabama (mandatory life without parole for juveniles). The District Court denied relief, and the Sixth Circuit certified a question of Tennessee law to this Court.
- The certified question: whether a defendant convicted of first‑degree murder committed on or after July 1, 1995 and sentenced to life under Tenn. Code Ann. § 39‑13‑202(c)(3) becomes eligible for release and, if so, after how many years.
- The controlling statutes are Tenn. Code Ann. § 40‑35‑501(h) (defines a life sentence as 60 years; release eligibility at 60% of 60 years but not before 25 years) and § 40‑35‑501(i) (for specified offenses committed on/after July 1, 1995, requires serving 100% of the sentence less credits but credits may not reduce the term by more than 15%).
- The Court held the statutory provisions are reconcilable: the determinate life term remains 60 years, but subsection (i) modifies release eligibility for post‑1995 offenses so that, after applying the 15% cap on credits, the earliest possible release is 51 years (60 years minus 15%).
Issues
| Issue | Plaintiff's Argument (Brown) | Defendant's Argument (Jordan/State) | Held |
|---|---|---|---|
| Whether a life sentence for first‑degree murder committed on/after 7/1/1995 makes a defendant eligible for release | Brown argued Miller challenge and ambiguity whether life = life without parole; asserted earlier release rules should apply | State argued subsections (h) and (i) must be read together and that subsection (i) increases the floor but preserves determinate 60‑year term | A defendant sentenced to life for first‑degree murder committed on/after 7/1/1995 is eligible for release no earlier than 51 years, when maximum allowable credits (capped at 15%) are applied |
| Whether § 40‑35‑501(h) was impliedly repealed by § 40‑35‑501(i) enacted in 1995 | Brown (and amici) urged rule of specificity or that (h) still controls for first‑degree murder | State (and AG opinion) had argued (i) created an irreconcilable conflict, implicitly repealing parts of (h) | The Court held no irreconcilable conflict exists; both subsections remain effective and are read harmoniously |
| How to compute earliest release date under the statutes | Brown sought application of release rules favorable to juvenile sentencing principles | State relied on statutory text: life = 60 years; (i) requires serving 100% less credits but credits capped at 15% | Court applied 60‑year determinate term reduced at most 15% (9 years), yielding earliest eligibility at 51 years |
| Precedential effect of prior opinions (Attorney General, Vaughn) | Brown noted Vaughn recognized uncertainty; urged relief consistent with Miller and statutory reading | State relied on Vaughn and AG opinion for interpretation | Court abrogated the portion of Vaughn endorsing an irreconcilable conflict; affirmed Vaughn’s result that post‑1995 offenders face 51‑year earliest eligibility |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (constitutionality of mandatory life without parole for juveniles)
- Vaughn v. State, 202 S.W.3d 106 (Tenn. 2006) (addressed release eligibility change for post‑1995 murders; abrogated to the extent it found an irreconcilable conflict between subsections)
- Baker v. State, 417 S.W.3d 428 (Tenn. 2013) (statutory construction principles; ascertain legislative intent)
- Womack v. Corr. Corp. of Am., 448 S.W.3d 362 (Tenn. 2014) (use of legislative history and broader statutory scheme when resolving ambiguity)