McDonald v. State
207 So. 3d 376
| Fla. Dist. Ct. App. | 2016Background
- Alfred McDonald, sentenced as an adult for a first-degree murder committed at age 16, received life imprisonment with the possibility of parole plus a consecutive 15-year term for armed robbery.
- McDonald filed postconviction motions under Fla. R. Crim. P. 3.800(a) and requested conversion to a 3.850(b)(2) claim, arguing his life-with-parole sentence was unconstitutional under Miller v. Alabama.
- The trial court denied his motions based on then-prevailing intermediate appellate precedent holding Miller did not apply to life-with-parole terms.
- Subsequent Florida Supreme Court and district court decisions clarified that Florida’s parole scheme does not afford the individualized consideration Miller requires and that juveniles with life-with-parole sentences are entitled to resentencing under chapter 2014-220.
- The Second District reversed the denial of McDonald’s Miller-based claim (and the conversion request), remanding for resentencing in conformity with sections 775.082, 921.1401, and 921.1402, while affirming denial of the second ground of his 3.800(a) motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether McDonald’s life with parole sentence for a murder committed at 16 violates Miller | McDonald: Miller prohibits mandatory life-without-parole–type sentences for juveniles; his life-with-parole is effectively equivalent and unconstitutional | State: Precedent held Miller did not apply to life-with-parole sentences because parole preserves a meaningful opportunity for release | Court: Miller applies; life-with-parole sentences that function like life without parole require resentencing under chapter 2014-220 |
| Whether the 3.800(a) claim should be converted to a 3.850(b)(2) claim | McDonald requested conversion to preserve the Miller claim | State opposed based on procedural posture and existing precedent at the time | Court reversed denial and allowed conversion/remand for resentencing consistent with statute |
Key Cases Cited
- Miller v. Alabama, 132 S. Ct. 2455 (U.S. 2012) (mandatory life-without-parole sentences for juveniles violate the Eighth Amendment)
- Horsley v. State, 160 So. 3d 393 (Fla. 2015) (remedy for unconstitutional juvenile life sentences is resentencing under chapter 2014-220)
- Atwell v. State, 197 So. 3d 1040 (Fla. 2016) (Florida’s parole scheme does not provide individualized juvenile consideration required by Miller; remand for resentencing)
- McPherson v. State, 138 So. 3d 1201 (Fla. 2d DCA 2014) (earlier decision applying the view that Miller did not apply to life-with-parole; later quashed by the Florida Supreme Court)