Rooks v. State
224 So. 3d 272
| Fla. Dist. Ct. App. | 2017Background
- Adolphus Rooks (born 1955) pleaded guilty in 1972 to sexual battery and was sentenced to life imprisonment with the possibility of parole.
- Rooks was released on parole in 1980 after serving ~8.5 years (age 24).
- He later violated parole multiple times and committed a new adult felony (trafficking in heroin in 2014). Parole was revoked in 2015 and he was returned to prison.
- Rooks moved to correct an illegal sentence, arguing that his juvenile life sentence violated the Eighth Amendment under Graham and Miller and their Florida applications (Henry and Atwell).
- Trial court denied relief; appellate court reviewed the record de novo and affirmed, concluding Rooks’ sentence did not meet the Graham/Miller threshold.
Issues
| Issue | Rooks’ Argument | State’s Argument | Held |
|---|---|---|---|
| Whether Rooks’ 1972 life-with-parole sentence for a juvenile implicates Graham/Miller (and Henry/Atwell) | Rooks: sentence is unconstitutional under Graham/Miller and Florida cases; he is entitled to resentencing under new juvenile-sentencing statutes | State: Rooks wasn’t sentenced to life without parole nor to an effective LWOP; he was paroled in 1980 and later violated parole as an adult, so Graham/Miller/Henry/Atwell don’t apply | Held: Not implicated. Rooks was sentenced to life with parole, obtained parole in 1980, and later committed new adult crimes; he cannot satisfy the threshold for Graham/Miller or Henry/Atwell and is not entitled to resentencing. |
Key Cases Cited
- Roper v. Simmons, 543 U.S. 551 (established juveniles cannot receive death penalty)
- Graham v. Florida, 560 U.S. 48 (juvenile nonhomicide LWOP unconstitutional; requires meaningful opportunity for release)
- Miller v. Alabama, 567 U.S. 460 (mandatory juvenile life-without-parole sentences unconstitutional; requires individualized sentencing)
- Montgomery v. Louisiana, 577 U.S. 190 (Miller announced a substantive rule that must be applied retroactively)
- Henry v. State, 175 So. 3d 675 (Fla. 2015) (Graham/Miller principles apply beyond literal "life" labels where sentence denies meaningful opportunity for release)
- Atwell v. State, 197 So. 3d 1040 (Fla. 2016) (life-with-parole sentence that effectively functions as LWOP falls within Graham/Miller and requires individualized consideration)
- Guzman v. State, 183 So. 3d 1025 (Fla. 2016) (juvenile who committed new crimes as an adult after probation/parole falls outside Graham relief)