154 So. 3d 561
La. Ct. App.2014Background
- G’Quan Baker was charged by indictment with three counts of second degree murder and one count of attempted second degree murder in Louisiana.
- A sanity commission found Baker competent to stand trial after a prior competency inquiry.
- Miller v. Alabama was raised to challenge the mandatory life-without-parole sentencing provision for juveniles; the trial court denied quash and Baker was convicted on all counts.
- On remand for counts 1, 3, and 4, the trial court sentenced Baker to life with parole eligibility after 35 years; count 2 received 15 years without parole, with all sentences concurrent.
- Baker filed pro se and counseled assignments of error challenging the indictment, competency ruling, and appellate record completeness; the court addressed these assignments.
- The appellate court affirmed all convictions and sentences, and found various pro se arguments moot or meritless.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Miller invalidate the 14:30.1 penalty for juveniles? | Baker argues Miller bars life without parole for juveniles | State contends Miller requires consideration, not blanket invalidation | Miller does not invalidate the statute; sentencing complied with Miller |
| Did the remand sentencing comply with Miller's requirements? | Baker contends sentencing did not follow Miller mandates | State argues the judge weighed youth factors per Miller and related guidelines | Court fully complied with Miller and related statutes on remand |
| Are Baker’s pro se challenges to the record moot or meritless? | Record incomplete; voir dire transcript missing | Record supplemented; sheets and transcripts now included | Assignments moot or meritless after supplementation |
| Was Baker's competency to stand trial properly determined? | Trial court lacked jurisdiction without competency | Sanity commission found competency; record supports | No merit; Baker was competent to stand trial |
Key Cases Cited
- Miller v. Alabama, 132 S. Ct. 2455 (U.S. 2012) (mandatory life without parole for juveniles invalid; requires consideration of youth)
- Graham v. Florida, 560 U.S. 48 (U.S. 2010) (opportunity for release based on maturity and rehabilitation)
- State v. Tate, 130 So.3d 829 (La. 2013) (Miller applies to sentencing, not conviction)
- State v. Drew, 360 So.2d 500 (La. 1978) (invalid death-penalty provision does not invalidate entire statute)
- State v. Burge, 362 So.2d 1371 (La. 1978) (prosecution valid despite invalidation of a penalty provision)