State of Indiana v. Matthew Stidham (mem. dec.)
18A02-1701-PC-68
| Ind. Ct. App. | Jun 14, 2017Background
- In 1991 Matthew Stidham (age 17) participated in a brutal attack that resulted in the victim being beaten, stabbed multiple times, and thrown into a river; Stidham was arrested and convicted of multiple felonies, including murder.
- After retrial, Stidham received aggregate sentences totaling 141 years; the Indiana Supreme Court affirmed convictions but remanded to vacate an auto-theft conviction as merged with robbery.
- In 2016 Stidham petitioned for post-conviction relief arguing his sentence violated the Eighth Amendment and Article 1, §16 of the Indiana Constitution given his juvenile status and new research on juvenile brain development.
- The post-conviction court granted relief, finding the sentence excessive in light of juvenile-sentencing jurisprudence (citing Miller and subsequent Indiana cases) and concluding the sentences should run concurrently for a total of 60 years.
- The State appealed, and the Court of Appeals found the post-conviction court failed to enter an "appropriate order with respect to the conviction or sentence" as required by Ind. Post-Conviction Rule 1(6), remanding for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Stidham's aggregate sentence is constitutionally excessive under Eighth Amendment/Miller-based juvenile standards | Stidham: juvenile status and subsequent research on adolescent brain development make a de facto life (141-year) sentence unconstitutional; mitigation and prison rehabilitation warrant relief | State: (implicit) original sentencing discretion and gravity of crimes justify original consecutive sentences; prior appeals upheld sentence reasonableness | Court: post-conviction court found sentence excessive under Miller-related reasoning and granted relief on that substantive ground |
| Whether the post-conviction court entered an appropriate, final order under Ind. Post-Conviction Rule 1(6) | Stidham sought relief from the sentence (proposed release/time served), but petition only argued unconstitutionality, not a specific remedy | State: contested adequacy of the relief and procedural correctness of the post-conviction order | Court: remanded because the post-conviction court granted relief but did not enter a specific, appropriate order correcting sentence or specifying release, as Rule 1(6) requires |
Key Cases Cited
- Stidham v. State, 637 N.E.2d 140 (Ind. 1994) (prior appeal affirming convictions and ordering merger of auto-theft with robbery)
- Stidham v. State, 608 N.E.2d 699 (Ind. 1993) (earlier opinion referenced in procedural history)
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (mandatory life without parole for juveniles unconstitutional; courts must account for youth)
- Brown v. State, 10 N.E.3d 1 (Ind. 2014) (applied Miller to limit imposition of extreme consecutive juvenile sentences)
- Hayden v. Keller, 134 F. Supp. 3d 1000 (E.D.N.C. 2015) (discussed de facto life sentences for juveniles as Eighth Amendment violations)