State
2014 WY 126
Wyo.2014Background
- Edwin Mares was convicted of felony (first‑degree) murder in 1995 for a crime committed at age 16 and was sentenced to life imprisonment; at that time Wyoming parole law made life sentences functionally without parole (parole only by gubernatorial commutation).
- Mares filed a Rule 35 motion (2013) asserting his mandatory life sentence for a juvenile violated the Eighth Amendment under Miller v. Alabama (2012).
- Wyoming amended its sentencing/parole statutes effective July 1, 2013, making juvenile life prisoners eligible for parole after 25 years and authorizing the Parole Board to consider such inmates.
- The State certified two legal questions to the Wyoming Supreme Court: (1) which test Wyoming should use to determine retroactivity of new constitutional rules on collateral review, and (2) whether Miller applies retroactively in Wyoming collateral proceedings; the State also raised mootness given the statutory change.
- The Court concluded the 2013 statutory amendments converted Mares’ effective sentence to life with parole eligibility after 25 years, but answered the certified questions to provide uniform guidance for pending similar challenges.
Issues
| Issue | Plaintiff's Argument (Mares) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Which retroactivity test should Wyoming adopt for collateral review? | Wyoming should apply a test that yields relief (both parties favored Teague but Mares argued broader relief may be appropriate). | State urged adoption of Teague framework. | Court adopts Teague v. Lane framework for collateral‑review retroactivity, while retaining ability to apply it more broadly for state interests. |
| Is Miller v. Alabama retroactive on collateral review in Wyoming? | Miller announces a substantive rule barring mandatory life‑without‑parole for juveniles and thus is retroactive under Teague. | Miller is procedural (not substantive) and not a Teague exception; thus not retroactive. | Court holds Miller announces a substantive rule and therefore applies retroactively on collateral review. |
| Does the 2013 statutory change render Mares’ Rule 35 motion moot? | Mares contended statute did not fully remedy Miller because it did not require individualized resentencing hearings. | State argued the statutory change converted life‑without‑parole to life with parole eligibility at 25 years, so Mares’ claim as framed is moot. | Court finds the statute converted Mares’ sentence to parole eligibility after 25 years, but declines to dismiss the certified questions as moot to avoid conflicting district rulings. |
Key Cases Cited
- Teague v. Lane, 489 U.S. 288 (establishes modern collateral‑review retroactivity framework)
- Schriro v. Summerlin, 542 U.S. 348 (distinguishes substantive rules from procedural rules for retroactivity)
- Roper v. Simmons, 543 U.S. 551 (juveniles cannot be executed; youth differences relevant to sentencing)
- Graham v. Florida, 560 U.S. 48 (life‑without‑parole for nonhomicide juveniles prohibited)
- Penry v. Lynaugh, 492 U.S. 302 (substantive rule includes forbidding certain punishments for a class of defendants)
- Atkins v. Virginia, 536 U.S. 304 (example of substantive Eighth Amendment rule affecting punishment)
- Danforth v. Minnesota, 552 U.S. 264 (states may adopt broader retroactivity rules than federal habeas Teague standard)
- Bear Cloud v. State (Bear Cloud II), 294 P.3d 36 (Wyo. 2013) (Wyoming decision recognizing practical effect of parole scheme as life‑without‑parole for juveniles)