People v. Padilla
4 Cal. App. 5th 656
| Cal. Ct. App. | 2016Background
- In 1999 Mario Salvador Padilla (age 16 at the time) was convicted of first‑degree murder (special circumstances) and sentenced to life without parole (LWOP) under Cal. Penal Code §190.5(b).
- Padilla sought resentencing after the U.S. Supreme Court’s decision in Miller v. Alabama (2012), which forbids mandatory LWOP for juveniles and requires consideration of youth‑related factors.
- The superior court held a resentencing hearing in July 2015 and reimposed LWOP; Padilla appealed.
- While the appeal was pending, the U.S. Supreme Court decided Montgomery v. Louisiana (2016), holding Miller announced a substantive rule retroactive on state collateral review and clarifying that Miller bars LWOP for all but the rare juvenile who is permanently incorrigible.
- On the evidence at resentencing the court emphasized the crime’s planning and brutality but did not expressly find permanent incorrigibility or resolve Miller factors in the manner Montgomery later required.
- The Court of Appeal reversed and remanded for a new resentencing hearing because the trial court had exercised discretion without the guidance Montgomery supplied.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Padilla) | Held |
|---|---|---|---|
| Whether Miller/Montgomery establish a categorical bar to LWOP for juvenile homicide offenders | Miller does not categorically bar LWOP; states retain discretion under §190.5(b) to impose LWOP after considering youth factors | Miller (and the logic of Roper/Graham) requires that LWOP never be imposed on juveniles | Court: No categorical bar; Miller declined to create one, and Montgomery treats Miller as announcing a substantive rule limiting LWOP to the rare permanently incorrigible juvenile |
| Whether Miller requires a particular procedure or express finding at resentencing | Trial court complied by considering Miller factors and could weigh them as it saw fit | Resentencing must follow Montgomery’s clarified standard and determine whether juvenile is permanently incorrigible | Court: Montgomery requires a procedure that resolves whether the juvenile’s crime reflects permanent incorrigibility; trial court here did not make that determination |
| Whether an LWOP imposed after a Miller resentencing hearing (pre‑Montgomery) is valid | If the court considered youth and attendant characteristics, the sentence may stand | A resentencing done without Montgomery’s guidance is inadequate and requires remand | Court: Because resentencing occurred before Montgomery clarified Miller’s substantive scope, remand for a new hearing is required |
| Remedy when resentencing occurred before Montgomery | Uphold if Miller factors were applied sufficiently | Remand for new hearing under Montgomery to allow defendant to show he falls within protected class | Court: Reverse and remand for resentencing consistent with Montgomery; court declines to decide on ultimate question of incorrigibility on appeal |
Key Cases Cited
- Roper v. Simmons, 543 U.S. 551 (2005) (juvenile death penalty unconstitutional; youth characteristics reduce culpability)
- Graham v. Florida, 560 U.S. 48 (2010) (LWOP for non‑homicide juvenile offenders unconstitutional)
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (Eighth Amendment forbids mandatory LWOP for juveniles; sentencer must consider youth‑related factors)
- Montgomery v. Louisiana, 136 S. Ct. 718 (2016) (Miller announced a substantive rule retroactive on collateral review; LWOP barred for all but the rare permanently incorrigible juvenile)
- People v. Gutierrez, 58 Cal.4th 1354 (2014) (California courts must consider Miller factors at §190.5(b) sentencing)
- People v. Palafox, 231 Cal.App.4th 68 (2014) (trial court satisfied Miller by giving due consideration to youth factors; later limited by Montgomery)
- People v. Blackwell, 3 Cal.App.5th 166 (2016) (applies Miller factors; court of appeal’s treatment discussed but not followed here)