People v. Contreras
229 Cal. Rptr. 3d 249
Cal.2018Background
- In 2011 two 16‑year‑olds, Leonel Contreras and William Rodriguez, kidnapped and brutally sexually assaulted two teenage girls; each was convicted under adult One Strike provisions and received aggregated long sentences.
- Rodriguez was sentenced to 50 years-to-life (two consecutive 25‑to‑life terms); Contreras to 58 years‑to‑life (two consecutive 25‑to‑life terms plus enhancements).
- The trial court acknowledged youth and mitigation but concluded the crimes justified very lengthy consecutive terms; both judges reduced effective exposure from statutory maxima as required by Graham/Caballero.
- The Court of Appeal affirmed convictions but held the sentences unconstitutional under Graham and remanded for resentencing with a parole-eligibility date consistent with Graham.
- The California Supreme Court granted review to decide whether 50‑ and 58‑year‑to‑life terms for juvenile nonhomicide offenders are the functional equivalent of LWOP under Graham and Caballero, and whether recent legislation (elderly parole, youth parole expansion) or conduct‑credit regulations affect that analysis.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Contreras/Rodriguez) | Held |
|---|---|---|---|
| Whether aggregated lengthy term‑of‑years sentences that afford parole eligibility late in life are the functional equivalent of LWOP under the Eighth Amendment | Sentences are constitutional so long as parole eligibility occurs within the defendant’s actuarial life expectancy (use CDC life tables) | Graham/Caballero require a meaningful, realistic opportunity for release and rehabilitation; parole at very advanced age (50+ years served) fails that test | Court: 50 and 58 years‑to‑life for juveniles are unconstitutional — they deny a meaningful opportunity for release under Graham/Caballero; remand for resentencing and setting parole‑eligibility dates consistent with that ruling |
| Whether life‑expectancy actuarial approach controls (use gender/race‑specific tables) | Life‑table approach yields administrable rule; parole within expected lifespan is sufficient | Such actuarial method is legally and practically problematic (group classifications, prison‑specific mortality, averages leave half without reaching expectancy); it fails Graham’s qualitative concerns | Court: Rejects simple actuarial life‑expectancy rule; emphasizes Graham’s substantive concerns about youth, capacity for change, incentives and reintegration |
| Whether the Elderly Parole Program or expanded youth parole/credit rules cure constitutional defect | Elderly parole and conduct‑credit regimes provide earlier opportunities (age 60 elderly parole; good‑conduct credits may advance dates) so sentences are not equivalent to LWOP | These programs may not ensure parole based on youth‑related rehabilitation, and statutory/regulatory details and practical operation must be examined | Court: Declines to resolve applicability of new statutes/regulations here; leaves to lower courts to develop record and consider their impact on resentencing |
| Whether Graham’s prohibition is limited to formal LWOP or extends to lengthy terms that foreclose meaningful release | Argues Graham only forbids formal LWOP; long terms with parole within life expectancy are acceptable | Graham’s rationale extends to de facto LWOP — sentences must provide realistic hope and opportunity to reintegrate; extremely long terms can be functionally equivalent to LWOP | Court: Graham’s reasoning extends to term‑of‑years sentences that, in practice, deny a meaningful opportunity for release; Caballero affirmed that principle and applied it here |
Key Cases Cited
- Roper v. Simmons, 543 U.S. 551 (juveniles are constitutionally different; capital punishment barred for juveniles)
- Graham v. Florida, 560 U.S. 48 (Eighth Amendment forbids LWOP for juvenile nonhomicide offenders; must provide meaningful opportunity for release)
- Miller v. Alabama, 567 U.S. 460 (mandatory LWOP for juveniles convicted of homicide unconstitutional; children are different for sentencing)
- Montgomery v. Louisiana, 577 U.S. (Miller announced a substantive rule applicable retroactively)
- People v. Caballero, 55 Cal.4th 262 (aggregate term‑of‑years that puts parole eligibility outside life expectancy can be the functional equivalent of LWOP)
- People v. Franklin, 63 Cal.4th 261 (availability of youth offender parole hearing under §3051 can preclude a Miller claim because it provides an opportunity for review)