LaMonte Martin v. Jessica Symmes
2015 U.S. App. LEXIS 5525
| 8th Cir. | 2015Background
- LaMonte Rydell Martin was convicted in Minnesota of first-degree murder committed at age 17 and received a mandatory life sentence without parole; the Minnesota Supreme Court affirmed and rejected a Batson challenge.
- Martin filed a §2254 habeas petition arguing (1) Miller v. Alabama requires retroactive relief from mandatory juvenile LWOP and (2) the prosecutor’s peremptory strike of Juror 43 (an African-American) violated Batson.
- While Martin’s petition was pending, the U.S. Supreme Court decided Miller v. Alabama, holding mandatory life without parole for juveniles convicted of homicide violates the Eighth Amendment.
- The district court denied relief but granted a certificate of appealability on Miller-retroactivity and Batson issues.
- The Eighth Circuit reviewed (a) whether Miller announced a new rule that must be applied retroactively under Teague exceptions and (b) whether the state courts’ Batson determination was an unreasonable factual finding under §2254(d).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Retroactivity of Miller | Miller should apply retroactively to Martin because it changes sentencing for juvenile homicide offenders and the Supreme Court applied it on collateral review in Jackson’s case | Miller announced a new procedural rule, not substantive or watershed, so under Teague it is not retroactive to cases final before Miller | Miller is a new procedural rule not qualifying as substantive or watershed; it is not retroactive to Martin under Teague |
| Whether Miller is substantive | Miller eliminates an entire sentencing line and effectively makes age an element, expanding sentencing outcomes | Miller requires a sentencing process (consider youth) but does not categorically bar LWOP for juveniles, so it is procedural | Miller is procedural because it mandates a process rather than prohibiting a punishment for a class of defendants |
| Watershed exception to Teague | Eighth Amendment juvenile-sentencing change implicates fundamental fairness and should be retroactive | No precedent has recognized any new procedural rule as watershed; Miller flows from existing precedents and does not affect conviction accuracy | Miller is not a watershed rule and therefore not retroactive |
| Batson challenge to Juror 43 | The prosecutor’s strike was race-motivated; juror’s views about racial disparities and a family conviction were pretexts and similarly situated white jurors were seated | Prosecutor offered race-neutral reasons (juror’s expressed bias about system, cousin’s possibly wrongful conviction, not forthcoming answers, work association with victim’s family) and reasons distinguishable from seated jurors | State court’s finding that the strike was race-neutral was not an unreasonable factual determination under §2254(d); Batson denial affirmed |
Key Cases Cited
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (mandatory juvenile life without parole unconstitutional; sentencer must consider youth)
- Teague v. Lane, 489 U.S. 288 (1989) (new rules generally not retroactive on collateral review; two exceptions)
- Batson v. Kentucky, 476 U.S. 79 (1986) (peremptory strikes based solely on race violate Equal Protection)
- Schriro v. Summerlin, 542 U.S. 348 (2004) (distinguishing substantive from procedural new rules for retroactivity)
- Whorton v. Bockting, 549 U.S. 406 (2007) (Teague exceptions defined: substantive or watershed procedural)
- Miller-El v. Cockrell, 537 U.S. 322 (2003) (Batson burden-shifting framework and standards for evaluating prosecutor’s explanations)
- Miller-El v. Dretke, 545 U.S. 231 (2005) (deference to state-court findings but review remains available where evidence shows purposeful discrimination)
- Purkett v. Elem, 514 U.S. 765 (1995) (prosecutor’s race-neutral explanation need not be persuasive or plausible; facial validity controls)