State v. Huntley
118 So. 3d 95
La. Ct. App.2013Background
- Darnell Huntley, a juvenile at the time of the offense, was convicted of first‑degree murder in 1982 and sentenced to life at hard labor without probation, parole, suspension, or commutation; conviction affirmed and sentence modified on direct appeal in 1983.
- In 2012 Huntley filed a motion to correct an illegal sentence arguing his mandatory life‑without‑parole sentence for a juvenile violated Miller v. Alabama (2012).
- The trial court held Miller applied retroactively and set Huntley for resentencing; the State sought supervisory review and the appellate court granted relief.
- The central legal question was whether Miller — which requires individualized sentencing consideration of youth before imposing mandatory life without parole for juveniles — applies retroactively on collateral review under Teague v. Lane.
- The appellate court concluded Miller announced a new, procedural rule (not a watershed or substantive rule that forbids a class of punishment) and therefore does not apply retroactively under Teague; the trial court’s retroactivity ruling was reversed and the writ was made peremptory.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miller applies retroactively on collateral review under Teague | State: Miller is not retroactive; it created a procedural rule that does not fall within Teague exceptions | Huntley: Miller should apply retroactively — either as substantive (prohibiting a punishment for a class) or as a watershed procedural rule | Held: Miller is a new procedural rule and is not retroactive under Teague |
| Whether Miller is substantive (removes a punishment for a class) | State: Miller did not categorically bar life without parole for juveniles, so it is not substantive | Huntley: Miller functionally removes a particular punishment for juveniles (life = functional death) | Held: Not substantive — Miller imposes procedural sentencing safeguards, not a categorical ban |
| Whether Miller is a "watershed" procedural rule under Teague | State: Miller is not watershed; it follows prior individualized‑sentencing jurisprudence | Huntley: Miller implicates reliability of sentencing for juveniles and is a watershed rule | Held: Not watershed — does not meet the narrow Teague exception |
| Effect of Supreme Court’s action in companion cases (e.g., Jackson) on retroactivity | State: Jackson’s relief was procedural in posture and does not itself establish retroactivity rule | Huntley: Relief to Jackson suggests Miller should be applied retroactively | Held: Relief in companion cases does not automatically make Miller retroactive; retroactivity requires a Supreme Court holding making the rule retroactive or fitting Teague exceptions |
Key Cases Cited
- Teague v. Lane, 489 U.S. 288 (1989) (framework for retroactivity on collateral review)
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory juvenile life‑without‑parole requires individualized sentencing consideration)
- Graham v. Florida, 560 U.S. 48 (2010) (Eighth Amendment prohibits life without parole for non‑homicide juvenile offenders)
- Roper v. Simmons, 543 U.S. 551 (2005) (death penalty unconstitutional for offenders under 18)
- Lambrix v. Singletary, 520 U.S. 518 (1997) (Teague first step: determine when conviction became final)
- Penry v. Lynaugh, 492 U.S. 302 (1989) (Teague exception: rules forbidding punishment of certain primary conduct)
- Tyler v. Cain, 533 U.S. 656 (2001) (Supreme Court must hold a rule retroactive to make it so under AEDPA framework)
- Caspari v. Bohlen, 510 U.S. 383 (1994) (state can raise Teague nonretroactivity; courts must apply Teague if State advances it)
- Schiro v. Farley, 510 U.S. 222 (1994) (State’s omission of Teague argument at cert stage can affect review of retroactivity)
- O'Dell v. Netherland, 521 U.S. 151 (1997) (discussion of Teague exceptions and scope)
- State v. Simmons, 99 So.3d 28 (La. 2012) (La. S. Ct. remanded for resentencing under Miller principles)
- State ex rel. Landry v. State, 106 So.3d 106 (La. 2013) (referencing Miller’s sentencing‑hearing requirement)
- People v. Carp, 298 Mich. App. 472 (Mich. Ct. App. 2012) (applying Teague and holding Miller not retroactive)
- People v. Williams, 982 N.E.2d 181 (Ill. App. Ct. 2012) (held Miller should be retroactive)
- People v. Morfin, 981 N.E.2d 1010 (Ill. App. Ct. 2012) (held Miller retroactive)
- In re Morgan, 713 F.3d 1365 (11th Cir. 2013) (held Miller not retroactive on collateral review)