State v. Fletcher
112 So. 3d 1031
La. Ct. App.2013Background
- Fletcher, a juvenile (15 at offense), killed both parents with a 12-gauge shotgun in his West Monroe home.
- Sister witnessed the killings; Fletcher threatened her and confiscated her phone to prevent notification.
- The next morning, Fletcher drove to school with the gun in the trunk and attended classes.
- He confessed after arrest, stating planning for about 1.5 months and intent to commit suicide that evening.
- Charged with two counts of second-degree murder; trial was moved venues and he was convicted on December 5, 2011.
- Sentencing on February 3, 2012 imposed two concurrent life sentences without probation, parole, or suspension, under a mandatory framework (14:30.1) despite PSI and Art. 894.1 review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constitutionality of mandatory life without parole for juveniles | Fletcher argues the statute infringes Graham/Miller. | State contends mandatory sentence permissible. | Sentence vacated and remanded for Miller-based resentencing. |
| Whether trial court adequately considered Miller factors under Art. 894.1 | Record insufficiently analyzes youth-related factors. | Court may rely on statutory guidelines without full articulation. | Remand for more thorough Miller-based consideration. |
| Impact of parole eligibility statute on juvenile second-degree murder cases | Parole options should be considered under Miller/Graham. | Statute applicable only to certain murders; not applicable here. | Statutory framework acknowledged; case remanded for proper Miller analysis. |
Key Cases Cited
- Graham v. Florida, 560 U.S. 48 (2010) (Eighth Amendment prohibits LWOP for nonhomicide juveniles; requires meaningful opportunity for release)
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (Mandatory LWOP for juveniles violates age-based considerations; allows individualized review)
- State v. Williams, 106 So.3d 1090 (La.App. 5 Cir. 2012) (Issue of parole for juveniles with LWOP as first impression in Louisiana)
- State v. Dorthey, 623 So.2d 1276 (La.1993) (Eighth Amendment proportionality review standard for punishments)
- State v. Young, 73 So.3d 473 (La.App. 2 Cir. 2011) (General rule on sentencing severity for worst offenders/offenses)
- State v. Cozzetto, 974 So.2d 665 (La.2008) (Abuse of discretion standard in reviewing sentences)
- State v. Lanclos, 419 So.2d 475 (La.1982) (Art. 894.1 factual basis should be adequate; not rigid compliance)
- State v. Jones, 398 So.2d 1049 (La.1981) (Consideration of personal history and offense in sentencing)