D. Steilman v. Michael
2017 MT 310
| Mont. | 2017Background
- In 1996, Derrick Steilman (age 17 years, 323 days) participated in a brutal, random murder in Montana; he later committed a second murder in Washington as an adult.
- Steilman pled guilty in Montana to deliberate homicide and was sentenced (1999) to 100 years for homicide plus 10 years for weapon use, consecutive — an aggregate 110 years with an express parole bar.
- The Montana court ordered the Montana term to run concurrent with a 23-year, 8-month Washington term (for the adult homicide), and Montana law then allowed day-for-day good-time credit, making theoretical release possible after 55 years (and less in practical effect due to concurrency/good time).
- Steilman filed a habeas petition arguing his aggregate sentence violated the Eighth Amendment under Miller and Montgomery because he was a juvenile at the time of the Montana offense and the sentencing court failed to account for youth-related mitigation.
- The State argued Miller applies only to mandatory life-without-parole schemes and that a term-of-years (110 years) is not necessarily the same as life without parole; it also emphasized Montana’s good-time allowance and the concurrent Washington sentence.
- The Montana Supreme Court agreed Miller/Montgomery apply to discretionary schemes and to de facto life terms, but held that Steilman’s practical exposure to incarceration (accounting for good-time and concurrent credit) did not make his Montana sentence a de facto life-without-parole sentence, and denied relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miller/Montgomery apply to Montana’s discretionary sentencing | Miller requires consideration of youth before imposing life-like punishments; applies regardless of mandatory/discretionary framework | Miller only targets mandatory LWOP schemes; Montana’s discretionary sentencing need not be invalidated | Court: Miller/Montgomery do apply to discretionary sentencing — sentencer must consider youth when imposing LWOP or its practical equivalent |
| Whether a lengthy term-of-years can count as a de facto life sentence triggering Miller | 110-year term with parole bar is effectively LWOP for a juvenile and thus triggers Miller protections | A term-of-years is distinct from de jure life; any year-term could theoretically equal life and thus rule would be unworkable | Court: Term-of-years can be de facto life in principle; Miller applies to practical equivalents of LWOP |
| Whether Steilman’s 110-year Montana sentence is a de facto LWOP | 110 years without parole is the practical equivalent of LWOP for a juvenile and requires Miller review | Concurrent Washington sentence and Montana good-time credit realistically reduce his exposure; he could be released far sooner, so not de facto LWOP | Court: Not a de facto LWOP here — good-time eligibility and concurrency mean Montana sentence does not, in practice, condemn him to die in prison; habeas denied |
| Remedy if sentence triggers Miller/Montgomery | Seek resentencing or restoration of parole eligibility under Miller/Montgomery | State would preserve original sentence where constitutionally allowable | Court did not reach remedy because it found no Miller violation on these facts; denial of habeas petition affirmed |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (establishes that life without parole for juveniles requires individualized consideration of youth and barred mandatory LWOP for most juveniles)
- Montgomery v. Louisiana, 136 S. Ct. 718 (announces Miller’s substantive rule is retroactive and emphasizes that juveniles must have a meaningful opportunity for release unless irreparable corruption is shown)
- Roper v. Simmons, 543 U.S. 551 (juvenile death penalty unconstitutional; recognizes developmental differences between juveniles and adults)
- Graham v. Florida, 560 U.S. 48 (categorically forbids LWOP for juveniles convicted of nonhomicide crimes; requires realistic opportunity for release)
- McKinley v. Butler, 809 F.3d 908 (7th Cir.) (discretionary life sentences must be guided by age-relevant considerations; supports Miller’s application to discretionary schemes)