387 P.3d 956
Okla. Crim. App.2016Background
- Chancey Allen Luna (16 at the time) shot and killed Christopher Lane on August 16, 2013; Luna was convicted by jury of First Degree Murder.
- Jury was charged with sentencing and returned punishment of life imprisonment without the possibility of parole; trial judge imposed that sentence.
- Defense presented minimal mitigation at trial (mother's brief testimony); trial court sustained objections to further mitigating evidence during guilt phase and limited defense argument about youth.
- Luna appealed, arguing his life-without-parole (LWOP) sentence is unconstitutional for juveniles under the Eighth Amendment and Oklahoma Constitution and that no individualized sentencing considering youth occurred.
- The State argued Miller/Montgomery inapplicable because Oklahoma does not mandate LWOP and the trial court had a sentencing hearing; the State also argued the district court considered relevant factors.
- The Court affirmed the conviction but vacated the LWOP sentence and remanded for resentencing because the sentencing jury had no meaningful opportunity/evidence to consider youth-related characteristics required by Miller and Montgomery.
Issues
| Issue | Luna's Argument | State's Argument | Held |
|---|---|---|---|
| Whether Eighth Amendment precludes LWOP for juvenile homicide offenders absent individualized consideration | LWOP unconstitutional for juveniles unless sentencer finds "irreparable corruption"/"permanent incorrigibility" beyond reasonable doubt | Miller/Montgomery inapplicable or satisfied here because Oklahoma sentencing is discretionary and there was a sentencing hearing | Miller/Montgomery apply; LWOP can be imposed only after individualized consideration of youth; Luna entitled to resentencing because no such consideration occurred |
| Whether Luna received constitutionally valid sentencing proceeding under Miller/Montgomery | Jury did not hear youth-related mitigation, so no valid individualized sentencing | Trial judge had sentencing hearing and could consider youth; jury sentencing statutory right but judge considered factors at formal sentencing | Record lacks evidence that jury (the sentencer) considered youth’s attendant characteristics; sentence vacated and remanded for resentencing |
| Whether failure to instruct on Second Degree Murder deprived due process | Requested instruction was warranted | Insufficient proof to support instruction | Instruction denial affirmed (no abuse of discretion) |
| Whether executive commutation is adequate remedy for Miller error | Commutation insufficient to vindicate Miller’s requirements | Same as plaintiff’s concession (State had argued commutation ok) | Court rejects commutation as adequate; requires a sentencing proceeding where youth-related evidence can be considered |
Key Cases Cited
- Graham v. Florida, 560 U.S. 48 (2010) (Eighth Amendment bars LWOP for juvenile nonhomicide offenders; requires meaningful opportunity for release)
- Miller v. Alabama, 567 U.S. 460 (2012) (Mandatory LWOP for juveniles unconstitutional; sentencer must consider youth and attendant characteristics)
- Montgomery v. Louisiana, 577 U.S. 190 (2016) (Miller applies retroactively and requires a procedure to separate rare irreparably corrupt juveniles from those whose crimes reflect transient immaturity)
- Roper v. Simmons, 543 U.S. 551 (2005) (death penalty unconstitutional for offenders under 18; foundational precedent on diminished culpability of juveniles)