Laisha L. Landrum v. State of Florida
192 So. 3d 459
| Fla. | 2016Background
- Laisha Landrum was 16 when convicted of second-degree murder (with a weapon) and sentenced to life imprisonment without parole under the pre-2014 Florida sentencing scheme.
- Under the 2004 statutes, second-degree murder was a life felony; life sentences imposed after 1983 in Florida carry no parole.
- At sentencing the judge gave no reasons or findings referencing youth-related mitigating factors; defense urged downward departure citing youth and other mitigators.
- The trial court sentenced Landrum to life without parole; postconviction relief was denied, and the Second District affirmed but certified a question of great public importance.
- Florida Supreme Court granted review to decide whether Miller v. Alabama requires individualized youth-focused sentencing consideration where a discretionary life-without-parole sentence was imposed without such consideration.
Issues
| Issue | Plaintiff's Argument (Landrum) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether Miller applies to discretionary life-without-parole sentences imposed on juveniles when the sentencer did not consider youth-related factors | Miller requires individualized consideration of youth before life without parole regardless of whether the sentence was mandatory or discretionary | Miller addressed mandatory schemes only; discretionary life sentences are not governed by Miller | Held for Landrum: Miller (and Montgomery) apply where a sentencer had discretion but did not consider youth; such sentences are unconstitutional unless individualized youth factors were considered |
| Whether Landrum’s life-without-parole sentence for second-degree murder violates the Eighth Amendment | Life without parole imposed without Miller factors is cruel and unusual for juveniles and violates proportionality principles | The prior discretionary sentencing scheme permitted life; Miller inapplicable | Held: Landrum’s sentence violated the Eighth Amendment and must be vacated; remand for resentencing under statutes implementing Miller |
| Proper remedy and retroactivity of Miller in Florida | Miller must be applied retroactively; remedy is resentencing under statutory scheme implementing Miller | State contested need to apply Miller to discretionary sentences imposed pre-2014 | Held: Miller is retroactive; resentencing required consistent with sections 775.082, 921.1401, and 921.1402 (2014) statutes |
| Whether sentencing juveniles to life must be rare and require a hearing considering “youth and attendant circumstances” | Juvenile life sentences must be rare; sentencer must distinguish transient immaturity from irreparable corruption via an individualized hearing | Life sentences can be imposed under discretion without a mandated Miller-style hearing | Held: Miller and Montgomery require that sentencing courts give due weight to youth-related evidence and that life without parole be uncommon; sentencing without such consideration is unconstitutional |
Key Cases Cited
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (mandatory life-without-parole for juveniles violates Eighth Amendment; requires individualized consideration of youth)
- Montgomery v. Louisiana, 136 S. Ct. 718 (2016) (Miller’s rule is substantive and retroactive; courts must consider youth before imposing life without parole)
- Graham v. Florida, 560 U.S. 48 (2010) (Eighth Amendment forbids life without parole for juvenile nonhomicide offenders; youth-related mitigation required)
- Roper v. Simmons, 543 U.S. 551 (2005) (death penalty unconstitutional for juvenile offenders; juveniles have diminished culpability)
- Falcon v. State, 162 So. 3d 954 (Fla. 2015) (Florida holds Miller retroactive and endorses Legislature’s 2014 remedial scheme)
- Horsley v. State, 160 So. 3d 393 (Fla. 2015) (approved the 2014 legislative sentencing scheme as the appropriate remedy to implement Miller in Florida)