State v. Andrews, 329 S.W.3d 369

Antonio Andrews, age 15 at the time, killed Officer Norvelle Brown during a street encounter in St. Louis.
A juvenile court certified Andrews to stand trial as an adult under Missouri's juvenile-certification statute § 211.071, transferring jurisdiction to general criminal court.
He was indicted for first degree murder and armed criminal action; the jury found him guilty of first degree murder and the court sentenced him to life without parole, plus a consecutive 50-year armed-criminal-action term.
Andrews challenged the certification procedure as Fact findings that enhance punishment under Apprendi, and challenged § 565.020 as cruel and unusual punishment for juveniles.
The trial record includes a videotaped statement where Andrews said he was tired of being chased before he shot the officer.
The court upheld the certification decision as not increasing the maximum punishment and affirmed the life-without-parole sentence, while dissents argued for remand to permit jury consideration of youth and mitigating factors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Apprendi applicability to certification	Andrews argues certification facts increase punishment requiring jury fact-finding.	Missouri's certification is jurisdictional, not punishment-enhancing.	Apprendi does not apply to certification proceedings.
Constitutionality of mandatory life without parole for juveniles	Missouri's scheme violates Eighth Amendment by denying parole consideration.	Youth is considered in certification; mandatory life without parole is permissible for homicide juveniles.	Missouri's scheme does not clearly violate the Eighth Amendment; remand not required here.
Sufficiency of evidence for first degree murder	State failed to prove deliberation/time to think beyond reasonable doubt.	Videotaped statements show cool reflection before killing.	Evidence supports a reasonable jury finding of deliberation for first degree murder.
Environmental impartiality during trial	Presence of uniformed officers compromised jury neutrality.	Non-preservation; no reversible error shown.	Issue preserved-untimely; no reversible error shown.

Apprendi v. New Jersey, 530 U.S. 466 (2000) (any fact increasing penalty beyond statutory maximum must be jury-found)
Blakely v. Washington, 542 U.S. 296 (2004) (maximum sentence based on facts found by jury, not judge)
Cunningham v. California, 549 U.S. 270 (2007) (mandatory judicial findings can't elevate term beyond verdict)
Ring v. Arizona, 536 U.S. 584 (2002) (aggravating factors for death penalty must be jury-found)
Graham v. Florida, 130 S. Ct. 2011 (2010) (juvenile life without parole for nonhomicide unconstitutional; mitigating age matters)
Roper v. Simmons, 543 U.S. 551 (2005) (death penalty for juveniles unconstitutional; life-without-parole discussed as alternative)
Oregon v. Ice, 555 U.S. 160 (2009) (sequential sentencing/credits context; Apprendi limits in offense-specific context)
McKeiver v. Pennsylvania, 403 U.S. 528 (1971) (no right to jury trial in juvenile proceedings)
In re Gault, 387 U.S. 1 (1967) (due process protections in juvenile adjudications)