Larry W. Newton, Jr. v. State of Indiana
83 N.E.3d 726
| Ind. Ct. App. | 2017Background
- In 1994, 17-year-old Larry W. Newton abducted and fatally shot 19-year-old Christopher Coyle; Newton later pled guilty to murder.
- Newton’s 1995 plea agreement: he would plead guilty to murder and receive life without parole (LWOP) in exchange for the State withdrawing its death-penalty request; the trial court retained discretion to accept the plea and ordered a presentence investigation.
- At sentencing the court heard mitigating and aggravating evidence (including Newton’s youth, abuse history, gang involvement, and victim-impact statements), expressly considered Newton’s youth and rehabilitation prospects, and concluded LWOP was appropriate.
- Newton filed successive post-conviction relief claiming LWOP for a juvenile violates the Eighth Amendment (relying on Miller and Montgomery) and that he could not have waived that right by plea; the trial court denied relief and the Court of Appeals affirmed.
- The Court of Appeals invoked appellate discretion to reach the merits despite waiver/res judicata arguments and held (1) a plea agreement to LWOP waives later challenge in this narrow context, and (2) even if Miller/Montgomery applied, the sentencing court satisfied the individualized-consideration requirement.
Issues
| Issue | Newton's Argument | State's Argument | Held |
|---|---|---|---|
| Whether LWOP imposed via Newton’s plea violates the Eighth Amendment under Miller/Montgomery | Miller/Montgomery render juvenile LWOP unconstitutional absent individualized consideration; Newton contends his LWOP is now invalid | Miller/Montgomery apply only to mandatory schemes; Newton voluntarily entered plea so rule doesn’t void his sentence | Court: Even if Miller/Montgomery applied, the sentencing court conducted the individualized analysis required and explicitly found Newton beyond rehabilitation; LWOP is constitutional here |
| Whether Newton waived his right to challenge LWOP by agreeing in plea to LWOP to avoid death penalty | A later change in law (Roper/statutory age changes) made the plea’s benefit illusory; he could not knowingly waive a right not yet recognized | Plea agreements are contractual and a defendant who received a present benefit at the time (avoidance of death) cannot later attack the agreed sentence | Court: Newton waived the claim—he received the benefit at the time of the plea; courts routinely treat such pleas as forfeiting later challenges; but the court nonetheless reached the merits |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (U.S. 2012) (mandatory juvenile LWOP sentences violate the Eighth Amendment because children are constitutionally different)
- Montgomery v. Louisiana, 136 S. Ct. 718 (U.S. 2016) (Miller announced a substantive rule that is retroactive; juveniles must have opportunity to show they are not irreparably corrupt)
- Roper v. Simmons, 543 U.S. 551 (U.S. 2005) (death penalty unconstitutional for crimes committed under age 18)
- Conley v. State, 972 N.E.2d 864 (Ind. 2012) (Indiana Supreme Court applying Miller principles and recognizing discretionary LWOP sentencing for juveniles can be constitutional when individualized consideration occurs)
- Stites v. State, 829 N.E.2d 527 (Ind. 2005) (defendant who benefits from plea cannot later attack the sentence as illegal)
- Fowler v. State, 977 N.E.2d 464 (Ind. Ct. App. 2012) (following Stites: plea benefit measured at time of agreement; forfeiture of later illegal-sentence claim)