State of West Virginia v. Isaiah Murphy
16-0362
| W. Va. | May 22, 2017Background
- Isaiah Murphy pled guilty pursuant to a global plea to two counts of robbery (first-degree/aggravated) and one count of burglary arising from three separate incidents involving a machete or knife and theft of prescription drugs and personal property.
- The State dismissed or agreed not to prosecute eleven other serious charges as part of the plea agreement.
- At the plea hearing Murphy was informed that each robbery count carried a statutory minimum of ten years and an open-ended maximum; the court warned potential exposure up to 100 years per robbery count.
- The circuit court ordered a pre-sentence investigation (PSI), which reported Murphy had a lengthy criminal history, prior unsuccessful alternative sentences, and a high risk of recidivism.
- The circuit court sentenced Murphy to 50 years for each robbery count (to run consecutively) and 1–10 years for burglary (concurrent), and Murphy appealed alleging the robbery sentences were disproportionate under Article III, Section 5 of the West Virginia Constitution.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Murphy's 50-year consecutive robbery sentences are disproportionate under WV Const. Art. III, §5 | Murphy: 50-year consecutive terms shock the conscience and are excessive relative to the crimes and his role | State/Circuit Ct: sentences within statutory bounds; aggravating factors (weapon use, criminal history, high recidivism risk) justify length | Court: No; under deferential review, sentences do not shock the conscience and pass objective proportionality review |
Key Cases Cited
- State v. Adams, 211 W.Va. 231, 565 S.E.2d 353 (W. Va. 2002) (articulates subjective and objective proportionality tests and upholds lengthy sentence for first-degree robbery)
- State v. Goodnight, 169 W.Va. 366, 287 S.E.2d 504 (W. Va. 1982) (sentences within statutory limits and not based on impermissible factors are not subject to appellate reversal)
- State v. Tyler, 211 W.Va. 246, 565 S.E.2d 368 (W. Va. 2002) (open-ended maximum statutes permit proportionality challenges under the state constitution)
- State v. Williams, 205 W.Va. 552, 519 S.E.2d 835 (W. Va. 1999) (upholds long sentences for violent property offenses; used for intra-jurisdictional comparisons)