State v. James, 371 N.C. 77

Background

Defendant (James) committed murder at age 16; convicted of first-degree murder and robbery; originally sentenced to mandatory life without parole (LWOP).
After Miller v. Alabama, North Carolina enacted N.C.G.S. §§ 15A-1340.19A–.19D to provide resentencing procedures for juveniles convicted of first-degree murder.
Trial court resentenced James to LWOP after a hearing considering statutory mitigating factors; Court of Appeals reversed for inadequate findings and held the statute created a presumption favoring LWOP but was constitutional.
North Carolina Supreme Court granted review to resolve whether the statute (1) creates a presumption of LWOP, (2) complies with Miller and Eighth Amendment due-process/vagueness concerns, and (3) violates ex post facto principles.
The Supreme Court held the statute does not unambiguously create a presumption for LWOP, upheld its constitutionality as drafted when read in context with Miller, and affirmed remand for further sentencing consistent with Miller and Montgomery.

Issues

Issue	Plaintiff's Argument (James)	Defendant's Argument (State)	Held
Whether N.C.G.S. § 15A-1340.19C creates a presumption in favor of LWOP for juveniles convicted of first-degree murder (non-felony-murder theories).	The statute’s use of "instead of" and limiting consideration to "mitigating factors" shows LWOP is the default and parole is only available if mitigation is shown.	Read in context and consistent with Miller, the statute presents two alternative sentences — LWOP or life with parole — to be chosen based on totality of circumstances; no presumption.	The Court held the statute does not clearly and unambiguously create a presumption for LWOP; sentencing judges must not presume LWOP and must decide using the factors and Miller’s standard.
Whether the Act violates the Eighth Amendment as interpreted in Miller and Montgomery (i.e., requires a presumption favoring life-with-parole or narrower findings to avoid arbitrary LWOP sentences).	A sentencing scheme must start with a presumption in favor of life with parole; absent required narrowing findings or aggravators, statute risks arbitrary LWOP sentences.	The statute implements Miller’s procedural protections (hearing; consideration of youth and enumerated mitigating factors) and provides sufficient guidance to avoid arbitrariness or vagueness.	The Court held the Act, construed in light of Miller, is not unconstitutionally vague or arbitrary and does not require formal aggravating-factor narrowing before LWOP.
Whether the Act constitutes an ex post facto law disadvantaging James by changing sentencing consequences after the offense.	Because pre‑Miller law lacked a savings clause, there was no constitutional sentence for juvenile first-degree murder at the offense date; James should be resentenced as if convicted of second-degree murder.	The Act preserves availability of the same punishment (LWOP) and makes a lesser sentence available; it is ameliorative and procedural, so it does not disadvantage the defendant.	The Court held there is no ex post facto violation: the Act does not increase punishment and is similar in logic to Dobbert.
Whether the trial court made adequate findings to support LWOP on resentencing.	Trial court’s resentencing order merely listed considerations without identifying which were mitigating/non‑mitigating; inadequate factfinding to support LWOP.	(State did not contest need for findings) The record must show considered application of statutory factors per Miller.	The Court of Appeals was correct to remand: trial court’s findings were insufficient; on remand the court must make adequate findings consistent with this opinion and Miller/Montgomery.

Key Cases Cited

Miller v. Alabama, 567 U.S. 460 (2012) (mandatory LWOP for juveniles violates Eighth Amendment; sentencing must consider youth and attendant characteristics)
Montgomery v. Louisiana, 577 U.S. 190 (2016) (Miller’s rule applies retroactively; LWOP must be rare and reserved for irreparably corrupt juveniles)
Roper v. Simmons, 543 U.S. 551 (2005) (death penalty unconstitutional for juveniles; juveniles are constitutionally different)
Graham v. Florida, 560 U.S. 48 (2010) (LWOP for nonhomicide juvenile offenders unconstitutional)
Dobbert v. Florida, 432 U.S. 282 (1977) (ameliorative, procedural post‑crime sentencing changes that preserve available punishments do not necessarily violate ex post facto clause)
Zant v. Stephens, 462 U.S. 862 (1983) (capital sentencing must narrow class eligible for death; relevant to debate over formal narrowing requirements)
Apprendi v. New Jersey, 530 U.S. 466 (2000) (constructs limits on judge-found facts increasing penalty; cited regarding jury‑finding arguments)
Blakely v. Washington, 542 U.S. 296 (2004) (further develops Sixth Amendment constraints on judge‑found facts affecting sentences)