Martez Brown v. State of Indiana, 10 N.E.3d 1

Background

In Nov. 2010, three teenagers (Martez Brown, 16; Na-Son Smith, 18; Jacob Fuller, 15) robbed Stephen Streeter and Keya Prince in their home; both victims were shot and killed during the robbery.
Brown gave an uncounseled, detailed statement to police implicating himself and the two co-defendants; he later recanted at trial.
Brown was charged as an adult with two counts of murder, robbery (Class A reduced to B), burglary (dismissed), and theft (not entered); he waived a jury and was convicted after a bench trial.
The trial court identified several aggravators (two deaths, criminal/delinquent history, offense committed in presence of a minor, probation violation, conspiracy) and limited mitigation (cooperation and youth), then imposed maximum sentences: 65 years for each murder and 20 years for robbery, all consecutive (aggregate 150 years).
On appeal the Indiana Supreme Court granted transfer solely to consider whether the aggregate sentence was inappropriate under Indiana Appellate Rule 7(B); the Court affirmed convictions but revised the sentence to concurrent 60-year terms for each murder plus consecutive 20 years for robbery (aggregate 80 years), and remanded for an amended sentencing order.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Brown’s 150-year aggregate sentence is appropriate under Ind. App. R. 7(B)	State argued maximum consecutive sentences were justified by aggravators and community impact	Brown argued his youth, accomplice role (did not necessarily pull trigger), childhood substance use, limited violent juvenile history, and cooperation warrant a lesser aggregate sentence	Court revised sentence: concurrent 60-year terms for murders + consecutive 20-year robbery = 80 years aggregate; convictions affirmed
Proper weight of juvenile characteristics at sentencing	State emphasized severity and community harm to support maximum punishment	Brown relied on juvenile-sentencing jurisprudence (Miller, Graham) and mitigating effect of youth/peer influence	Court applied juvenile culpability principles and reduced aggregate sentence, noting juvenile differences and rehabilitative considerations
Role of accomplice liability in sentencing severity	State treated Brown as equally culpable under accomplice theory	Brown stressed record suggested co-defendants likely fired the shots, reducing moral culpability	Court found accomplice status a strong factor favoring revision and reduced sentence consistent with precedents recognizing lesser penalty may be appropriate for accomplices
Use of community outrage as sentencing rationale	State/trial court invoked community outrage to justify powerful response	Brown contended community outrage should not drive sentence; appellate precedent disapproves such consideration	Court criticized using community outrage and disapproved considering it in sentencing; relied on individualized sentencing factors instead

Key Cases Cited

Pierce v. State, 949 N.E.2d 349 (Ind. 2011) (recognizing Indiana Supreme Court’s authority to independently review and revise sentences)
Anglemyer v. State, 868 N.E.2d 482 (Ind. 2007) (standards for appellate review of sentencing; App. R. 7(B) framework)
Castillo v. State, 974 N.E.2d 458 (Ind. 2012) (reducing sentence where defendant convicted as accomplice lacked proof she knowingly killed)
Graham v. Florida, 560 U.S. 48 (2010) (juveniles are less culpable than adults; life without parole for nonhomicide juvenile offenders unconstitutional)
Miller v. Alabama, 132 S. Ct. 2455 (2012) (mandatory life without parole for juveniles unconstitutional; courts must consider youth-related differences)
Cardwell v. State, 895 N.E.2d 1219 (Ind. 2008) (Appellate R. 7(B) revision reflects appellate court’s collective sense of appropriate aggregate sentence)
Taylor v. State, 840 N.E.2d 324 (Ind. 2006) (heinousness aggravator requires brutal facts; single-shot accomplice killing did not warrant such an enhancement)
Carter v. State, 711 N.E.2d 835 (Ind. 1999) (reduced juvenile’s maximum sentence based in part on youth)
Walton v. State, 650 N.E.2d 1134 (Ind. 1995) (reduced lengthy aggregate sentence for juvenile offender)
Widener v. State, 659 N.E.2d 529 (Ind. 1995) (reduced multi-decade juvenile sentence based on additional mitigating factors and aggregate review)
Roper v. Simmons, 543 U.S. 551 (2005) (juveniles less mature and more susceptible to influence; relevant to culpability and sentencing)