Haughey v. Commissioner of Correction
164 A.3d 849
Conn. App. Ct.2017Background
- In 2003 Norman Haughey (age 25) fatally attacked two women during a burglary; he was convicted and sentenced to life imprisonment without possibility of release under Conn. Gen. Stat. § 53a-35a.
- Haughey filed a habeas petition alleging (1) ineffective assistance of trial and appellate counsel and (2) his mandatory life-without-parole sentence is cruel and unusual under the Eighth Amendment; he amended the petition and proceeded to trial on the merits.
- At the habeas trial Haughey presented evidence (his testimony and three experts) about childhood abuse, long-term substance and steroid use, and neuroscientific testimony about continued brain development into the mid-20s.
- The habeas court denied relief and refused certification to appeal; Haughey appealed that denial, claiming Miller v. Alabama entitles him to an individualized sentencing inquiry despite being 25 at the time of the offenses.
- He also raised, for the first time on appeal, a Connecticut constitutional due process claim (Art. I, §§ 8 & 9) challenging his mandatory sentence; the appellate court declined to consider that claim because it was not presented to the habeas court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miller v. Alabama requires individualized sentencing protections for offenders age 18–25 | Haughey: youth-related immaturity and neuroscience extend past 18, so Miller protections should apply at 25 | State: Miller and related precedent are limited to those under 18; chronological age is the boundary | Court: Miller protections apply only to juvenile offenders under 18; no abuse of discretion in denying certification |
| Whether life without parole violates Connecticut Constitution (Art. I, §§ 8 & 9) | Haughey: (raised on appeal) state constitutional protections independently bar mandatory life without release | State: claim not raised below; cannot be reviewed on appeal from denial of certification | Court: Declined to review—issue not presented to habeas court or in petition for certification |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life-without-parole for homicide offenders under 18 requires individualized sentencing considering youth mitigating factors)
- Roper v. Simmons, 543 U.S. 551 (2005) (death penalty unconstitutional for offenders under 18; age 18 is the bright-line for juvenile/adult distinction)
- Graham v. Florida, 560 U.S. 48 (2010) (life without parole for nonhomicide juvenile offenders violates Eighth Amendment)
- State v. Riley, 315 Conn. 637 (2015) (applies Miller principles to Connecticut juvenile sentencing)
- State v. Taylor G., 315 Conn. 734 (2015) (reviews Miller/Graham/Roper framework and juvenile sentencing principles)
- Simms v. Warden, 229 Conn. 178 (1994) (standards for appellate review after denial of certification to appeal from habeas)
- United States v. Marshall, 736 F.3d 492 (6th Cir. 2013) (refused to extend Miller protections to an adult despite expert testimony about developmental immaturity)