State v. Ames, 836 S.E.2d 296

On Sept. 27, 2015, 17‑year‑old Kamani Ames was present when 18‑year‑old Nahcier Brunson shot and killed 17‑year‑old Unique Graham; Brunson was the shooter and later pled guilty to first‑degree murder.
Ames initially told police he was present but not the shooter; a gun found in his home was admitted by Ames to have been used in the killing; a jail “kite” and an inmate’s testimony suggested Ames attempted to influence Brunson’s statements.
A jury convicted Ames of first‑degree murder; at a brief sentencing hearing Ames presented mitigation (mother’s testimony, no prior record, completed high‑school while jailed, not the shooter, potential for rehabilitation).
The trial court found only two statutory mitigating factors (age and no prior record), concluded Ames manipulated Brunson and engineered a scheme to lure the victim, compared Ames’ prospects to the general class of first‑degree murderers, and imposed life without parole (LWOP).
On appeal Ames argued the court applied the wrong legal standard for sentencing a juvenile to LWOP (Eighth Amendment / Miller line of cases); the Court of Appeals agreed, holding the court failed to apply Miller/Montgomery’s individualized ‘‘irreparable corruption’’ inquiry and improperly compared the juvenile to adult offenders.
Result: judgment vacated and case remanded for re‑sentencing consistent with Miller/Montgomery and N.C. Gen. Stat. §15A‑1340.19B.

Issue	State's Argument	Ames's Argument	Held
Whether the trial court applied the correct Eighth Amendment/Miller standard when sentencing a juvenile to LWOP	The court lawfully weighed mitigating factors and could impose LWOP based on the offense and manipulative role	The court used the wrong legal standard by focusing on the offense and failing to assess whether Ames is among the ‘‘rare’’ juveniles who reflect irreparable corruption	Court of Appeals: trial court applied incorrect standard; must assess Miller/Montgomery inquiry (whether crime reflects irreparable corruption)
Whether it was permissible to compare juvenile defendant’s rehabilitative prospects to adult murderers	Comparison to adult offenders is a permissible part of weighing mitigation and facts	Comparing a juvenile to adults contravenes the principle that children are constitutionally different and undermines Miller’s protective focus	Court of Appeals: comparing juvenile to adult offenders was improper and inconsistent with Miller line of cases
Appropriate remedy after legal‑standard error	State argued LWOP was justified and that remand or affirmance was appropriate	Ames asked for entry of life with parole (or remand for resentencing)	Court vacated LWOP judgment and remanded for re‑sentencing; did not substitute a new sentence itself

Roper v. Simmons, 543 U.S. 551 (2005) (death penalty for offenders under 18 violates Eighth Amendment; juveniles are constitutionally different from adults)
Graham v. Florida, 560 U.S. 48 (2010) (LWOP for juveniles in non‑homicide cases violates Eighth Amendment)
Miller v. Alabama, 567 U.S. 460 (2012) (mandatory LWOP for juveniles in homicide cases unconstitutional; requires individualized sentencing that accounts for youth)
Montgomery v. Louisiana, 136 S. Ct. 718 (2016) (Miller announced a substantive rule that applies retroactively; LWOP for juveniles only for the rare offender whose crime reflects irreparable corruption)
State v. James, 371 N.C. 77 (N.C. 2018) (upheld §15A‑1340.19B as constitutional and directed trial courts to apply Miller’s substantive standard; LWOP for juveniles should be rare)
Harmelin v. Michigan, 501 U.S. 957 (1991) (describes LWOP as among the most severe punishments and discusses proportionality analysis)