Hayden v. Keller
134 F. Supp. 3d 1000
| E.D.N.C. | 2015Background
- Shaun Hayden, convicted as an adult for crimes committed at age 15, is serving a life sentence with parole eligibility; he has been denied parole at the initial review every year since becoming eligible in 2002.
- Hayden sued under 42 U.S.C. § 1983 seeking declaratory and injunctive relief, alleging North Carolina’s parole procedures deny juvenile offenders a "meaningful opportunity" for release as required by Graham and Miller.
- North Carolina’s Parole Commission uses a two-step review (initial "review" and, if not denied, an "investigation"), treats juvenile and adult cases identically, and commissioners do not consider age-at-offense; case analysts prepare summaries and recommendations, with very high caseloads.
- The initial review rarely results in parole or advancement to level-two investigation; level-two provides notice and a psychological evaluation but few juvenile lifers reach that stage.
- Statistical and expert evidence shows juvenile lifers are rarely paroled; parole determinations emphasize crime brutality and infraction history; one analyst record indicated youth was treated negatively as a risk factor.
- The district court found North Carolina’s parole process, as applied to juvenile offenders serving life with parole, fails to provide the Graham-required meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Graham requires a parole process that gives juvenile nonhomicide lifers a "meaningful opportunity" for release | Hayden: Graham requires meaningful, age‑aware parole review where maturity/rehabilitation can be shown | Defendants: No constitutional right to parole beyond statutory consideration; Greenholtz allows mere hope of parole | Court: Graham’s Eighth Amendment mandate applies; NC parole process fails to provide the meaningful opportunity Graham requires |
| Whether NC Parole Commission’s procedures consider youth and youth-related characteristics | Hayden: Commission does not consider age at offense, offers no notice or hearing, and is passive — so juveniles cannot show maturation | Defendants: Parole review procedure is lawful and neutral; due process only requires reasons for denial | Court: Commission’s uniform adult-oriented process and failure to consider youth characteristics violates Graham/Miller principles |
| Whether statistical/practical operation of parole system renders parole de facto life without parole for juveniles | Hayden: Low parole rates for juvenile lifers and procedural hurdles make release illusory | Defendants: Denials reflect discretion and case facts, not systemic constitutional defect | Court: Data and practices demonstrate the process is not meaningful and can function as de facto life without parole for juveniles |
| Remedy required and next steps | Hayden: Injunctive relief to make parole process Graham‑compliant | Defendants: Current regime is lawful; no sweeping relief necessary | Court: Declines to enter specific injunction; denies summary judgment to defendants, grants in part for Hayden (finding constitutional violation) and gives parties 60 days to propose mechanisms to comply with Graham |
Key Cases Cited
- Graham v. Florida, 560 U.S. 48 (2010) (Eighth Amendment bars life without parole for juvenile nonhomicide offenders; state must provide a meaningful opportunity for release based on maturity and rehabilitation)
- Miller v. Alabama, 567 U.S. 460 (2012) (juveniles are constitutionally different; sentencers must consider youth and its characteristics before imposing life without parole)
- Greenholtz v. Nebraska Penal Inmates, 442 U.S. 1 (1979) (no constitutional right to parole; due process requires procedural protections tailored to the situation)
- Vann v. Angelone, 73 F.3d 519 (4th Cir. 1996) (states need not provide parole, and due process may be satisfied by statement of reasons for denial)
- Greiman v. Hodges, 79 F. Supp. 3d 933 (S.D. Iowa 2015) (Miller/Graham protections apply where parole/sentencing produces de facto life without parole; requires meaningful opportunity to demonstrate rehabilitation)