State v. Charles, 2017 S.D. 10

Background

In 1999, 14-year-old Daniel Charles shot and killed his stepfather; a jury convicted him of first-degree murder and he received a mandatory life sentence in 2000.
Charles filed a motion to correct an illegal sentence after Miller v. Alabama (2012); the circuit court granted relief in 2015 and held a resentencing hearing.
At the 2015 resentencing (same judge who presided at trial), both parties presented expert testimony about Charles’s youth, psychological traits, and rehabilitation; victim-impact statements and many written victim letters were received.
The court found chronic antisocial traits and that the crime was premeditated rather than impulsive, credited Charles with time served (about 16 years), and resentenced him to 92 years with parole eligibility at age 60.
Charles appealed, raising five issues: categorical unconstitutionality of the 92-year term for a 14‑year‑old, whether it is the functional equivalent of life without parole, whether the court failed to give proper weight to Miller’s mitigating youth factors, whether the sentence is grossly disproportionate, and whether admitting a cousin’s oral victim-impact statement (outside the statutory victim definition) was error.

Issues

Issue	Charles's Argument	State's Argument	Held
1) Is a 92‑year sentence categorically unconstitutional for a 14‑year‑old?	A 14‑year‑old is developmentally distinct and a death‑in‑prison result is categorically barred.	Supreme Court has not declared discretionary long terms categorically prohibited for juveniles.	No categorical bar; discretionary long terms are not per se unconstitutional.
2) Is 92 years the legal/functional equivalent of life without parole?	Though parole eligibility exists at 60, release then is effectively geriatric and not a meaningful opportunity for reentry.	Parole eligibility at 60 gives a realistic/meaningful opportunity for release; not a de facto life sentence.	Not a de facto life sentence; parole eligibility at 60 avoids a guaranteed life term.
3) Did the court disregard Miller’s mitigating youth qualities?	The court superficially listed Miller factors and overemphasized incapacitation; it ignored evidence of maturation and lack of prison violence.	The court thoroughly considered Miller factors, expert testimony, and the judge’s personal knowledge of Charles; credibility and weight findings were proper.	No error; court applied Miller, weighed evidence, and did not abuse discretion.
4) Is the 92‑year sentence grossly disproportionate to the offense?	Given youth and mitigation, the term is excessive compared to other juvenile sentences.	The murder was severe, premeditated, and the sentence (with parole eligibility) falls within the permitted spectrum; no gross disproportionality.	Not grossly disproportionate; threshold comparison does not indicate an Eighth Amendment violation.
5) Was admitting an oral victim‑impact statement by a cousin (not statutorily a "victim") erroneous and prejudicial?	The cousin was outside SDCL 23A‑27‑1.1 and her inflammatory remarks prejudiced sentencing.	Court has broad discretion at sentencing; other victim statements and letters with similar content reduced any prejudice.	Even if admission was improper, it was not so unduly prejudicial as to render the proceeding fundamentally unfair.

Key Cases Cited

Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life without parole for juveniles unconstitutional; courts must consider mitigating qualities of youth)
Roper v. Simmons, 543 U.S. 551 (2005) (death penalty for juvenile offenders barred)
Graham v. Florida, 560 U.S. 48 (2010) (life without parole barred for nonhomicide juvenile offenders; requires meaningful opportunity for release)
Montgomery v. Louisiana, 136 S. Ct. 718 (2016) (Miller applies retroactively)
Payne v. Tennessee, 501 U.S. 808 (1991) (victim‑impact evidence at sentencing permissible under Eighth Amendment)
Harmelin v. Michigan, 501 U.S. 957 (1991) (Eighth Amendment forbids only sentences that are "grossly disproportionate")
Solem v. Helm, 463 U.S. 277 (1983) (proportionality framework for Eighth Amendment challenges)
State v. Springer, 856 N.W.2d 460 (S.D. 2014) (South Dakota discussion of de facto life sentences and Miller application)
State v. Chipps, 874 N.W.2d 475 (S.D. 2016) (framework for gross disproportionality review)
State v. Diaz, 887 N.W.2d 751 (S.D. 2016) (juvenile sentence with parole eligibility at 55 not de facto life)
United States v. Jefferson, 816 F.3d 1016 (8th Cir. 2016) (declining to treat lengthy term‑of‑years as categorically barred under Miller)