People v. Vigil, Jr, 372 P.3d 1045

In 1997 Frank Vigil Jr., at age 16, was convicted of first-degree murder for the kidnapping, rape, torture, and murder of a 14-year-old and was sentenced to life without parole (statutory mandatory sentence for crimes between 1990–2006).
Vigil’s conviction became final after direct appeal and denial of certiorari.
In 2013 Vigil filed a Crim. P. 35(c) motion seeking relief under Miller v. Alabama, arguing that mandatory life-without-parole for juveniles is unconstitutional.
The trial court concluded Miller applied retroactively on collateral review and granted Vigil’s motion, ordering relief.
The People petitioned this court under C.A.R. 50, arguing Miller does not apply retroactively; the Colorado Supreme Court granted review and decided the matter in light of Jensen v. People.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Miller v. Alabama applies retroactively on collateral review to final judgments	Vigil: Miller announces a substantive rule that prohibits mandatory LWOP for juveniles and thus should apply retroactively	People: Miller is a procedural rule and does not apply retroactively on collateral review of final judgments	Miller does not apply retroactively to cases on collateral review of a final judgment (per Jensen)
Whether the trial court properly granted a new sentencing hearing if Miller applied retroactively	Vigil: If Miller applies, a new sentencing (or individualized) hearing is required	People: Not reached because court determined Miller not retroactive; thus no relief warranted	Court did not reach merits because it held Miller is not retroactive; trial court's grant of relief reversed

Miller v. Alabama, 567 U.S. 460 (2012) (held that mandatory life-without-parole for juvenile homicide offenders violates the Eighth Amendment)
Jensen v. People, 352 P.3d 959 (Colo. 2015) (Colorado Supreme Court held Miller does not apply retroactively on collateral review of a final judgment)