Roman Nose v. State
845 N.W.2d 193
Minn.2014Background
- Roman Nose was 17 years and 10 months when he killed Jolene Studemann in July 2000 and was convicted in 2001 of first-degree murder and related crimes.
- He was sentenced to life without the possibility of release (LWOR) under Minn. Stat. § 609.106, subd. 2(1).
- Direct appeal in 2003 affirmed his conviction; no challenge to his LWOR sentence was raised at that time.
- Miller v. Alabama (2012) held juveniles cannot be mandatorily sentenced to LWOR without considering age-related mitigating factors.
- Roman Nose filed a postconviction petition in 2012–2013 asserting Miller’s retroactive application, which the postconviction court granted, resentencing him to LWOR with release after 30 years.
- The Minnesota Supreme Court reversed, held Miller not retroactive under Chambers, and reinstated the LWOR sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State’s appeal is moot. | State seeks reversal of the postconviction relief. | Roman Nose argues relief cannot be granted without violating Eighth Amendment; mootness prevents relief. | Not moot; this Court can grant effective relief by reinstating LWOR. |
| Whether Miller retroactively applies to a juvenile whose LWOR final before Miller. | Roman Nose contends Miller is retroactive. | State argues Miller is not retroactive under Chambers. | Miller does not apply retroactively to Roman Nose under Chambers. |
| Whether the postconviction court erred in denying relief under supervisory powers. | Roman Nose seeks relief under supervisory powers due to unjust LWOR imposition. | State argues no exceptional circumstances to invoke supervisory powers. | Rejected; supervisory relief not warranted given lack of exceptional circumstances and retroactivity ruling. |
| Whether the postconviction time-bar applies given Miller retroactivity questions. | Roman Nose relied on Miller’s retroactive interpretation. | Chambers controls; Miller not retroactive, so time-bar applies. | Time-bar not extended; Miller retroactivity not recognized; petition time-bar stands. |
Key Cases Cited
- Chambers v. State, 831 N.W.2d 311 (Minn.2013) (Miller not retroactive for pre-Miller LWOR sentences; Teague analysis applied by Minnesota.)
- Miller v. Alabama, 132 S. Ct. 2455 (U.S.2012) (Mandated consideration of age in juvenile LWOR; not automatically retroactive.)
- Teague v. Lane, 489 U.S. 288 (U.S.1989) (Established retroactivity framework for new constitutional rules.)
- Danforth v. State, 761 N.W.2d 493 (Minn.2009) (Discussed fairness considerations within Teague framework.)
- Padilla v. Kentucky, 559 U.S. 356 (U.S.2010) (Cited regarding retroactivity analysis and procedural/constitutional rules.)
- Campos v. State, 816 N.W.2d 480 (Minn.2012) (Discussed retroactivity posture when issues raised by retroactivity not briefed.)
- Gideon v. Wainwright, 372 U.S. 335 (U.S.1963) (Fundamental fairness baseline in constitutional analysis.)