Estrada-Huerta v. People
2017 CO 52
| Colo. | 2017Background
- In 2004, when he was 17, Alejandro Estrada-Huerta participated in the abduction and repeated sexual assaults of a 15-year-old; he was prosecuted as an adult.
- A jury convicted him of second-degree kidnapping and sexual assault; after merger of counts the trial court imposed 24 years for kidnapping and 16-to-life for each of two sexual-assault counts, the latter running concurrently with each other but consecutively to the kidnapping sentence.
- The aggregate sentence was 40 years to life (i.e., parole eligibility after 40 years), meaning Estrada-Huerta will be eligible for parole at about age 58.
- After Graham v. Florida (prohibiting LWOP for nonhomicide juvenile offenders), Estrada-Huerta moved under Colo. Crim. P. 35(c) arguing his aggregate term-of-years is a de facto life without parole sentence and therefore unconstitutional.
- The district court denied relief; the Colorado Court of Appeals affirmed, reasoning parole eligibility at age 58 falls within his expected life span and thus provides a meaningful opportunity for release under Graham.
- The Colorado Supreme Court granted certiorari and affirmed the court of appeals, holding (as in the companion case Lucero) that Graham and Miller do not apply to, and therefore do not invalidate, aggregate consecutive term-of-years sentences imposed on juveniles.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Graham and Miller invalidate an aggregate consecutive term-of-years sentence imposed on a juvenile | Estrada-Huerta: aggregate 40-to-life is functionally LWOP and denies a meaningful opportunity for release | People: Graham/Miller apply only to an explicit LWOP sentence, and an aggregate term with parole eligibility is not LWOP | Court: Affirmed on separate grounds — Graham and Miller do not apply to aggregate term-of-years sentences (see Lucero companion reasoning) |
| Whether parole eligibility within the offender’s life expectancy satisfies Graham’s meaningful-opportunity requirement | Estrada-Huerta: aggregate may still be de facto LWOP despite parole eligibility | People/Ct. of Appeals: parole eligibility at age 58 is within life expectancy, so provides a meaningful opportunity for release | Court: Agrees that parole eligibility within expected lifetime can satisfy Graham (concurrence); majority rests decision on inapplicability of Graham/Miller to term-of-years sentences |
Key Cases Cited
- Graham v. Florida, 560 U.S. 48 (2010) (Eighth Amendment bars life without parole for nonhomicide juvenile offenders)
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life-without-parole for juveniles unconstitutional)
- Lucero v. People, 394 P.3d 1128 (Colo. 2017) (companion Colorado Supreme Court decision holding Graham and Miller do not apply to aggregate consecutive term-of-years sentences)