State v. Jones
297 Neb. 557
| Neb. | 2017Background
- In 1999 Daniel Lee Jones (age 16 at the time of the crime) pled no contest to first-degree murder for a premeditated, coordinated stabbing and was sentenced to life imprisonment.
- After Miller v. Alabama, Jones moved for postconviction relief; his life sentence was vacated in 2015 and the case set for resentencing under the juvenile-sentencing framework.
- At the 2016 mitigation/resentencing hearing, Jones presented expert testimony on adolescent brain development, a psychological evaluation finding low risk of future violence, family testimony about a chaotic, violent upbringing, and good institutional behavior.
- The district court considered statutory mitigating factors (Neb. Rev. Stat. § 28-105.02), Miller/Montgomery principles, Jones’s conduct in prison, and the violent, planned nature of the offense.
- The court resentenced Jones to 80 years to life with parole eligibility at age 56; Jones appealed claiming the sentence was effectively life without parole, that the court failed to make specific findings about youth-related factors, and that the sentence was disproportionate.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 80-to-life with parole eligibility at 56 is a de facto life-without-parole sentence | Jones: parole at 56 is effectively life without parole given life expectancy and therefore violates Miller/Eighth Amendment | State: parole eligibility, district court’s consideration of youth and hope for release, and precedent allow such a sentence | Court: Not unconstitutional; parole eligibility at 56 provides a "meaningful and realistic opportunity" for release under precedent (Smith) |
| Whether due process/Miller required specific written findings about age-related characteristics or "irreparable corruption" | Jones: court failed to make specific findings demonstrating adequate consideration of age-related factors | State: Miller does not require formalized factfinding where parole remains possible; court need only consider statutory and Miller factors | Court: No error; specific findings not required because sentence was not life without parole; consideration of §28-105.02 factors sufficed (Garza/Mantich jurisprudence) |
| Whether the 80-to-life sentence is disproportional/excessive under the Eighth Amendment | Jones: youth and evidence of maturation/reform show diminished culpability and make the sentence disproportionate | State: the murder was planned, brutal, and followed by concealment; severity warranted a lengthy sentence despite youth | Court: Sentence not grossly disproportionate; facts showed calculated, malicious conduct and concealment; sentence appropriate |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life without parole for juveniles violates the Eighth Amendment and requires individualized consideration)
- Montgomery v. Louisiana, 136 S. Ct. 718 (2016) (Miller applies retroactively and requires consideration of juvenile characteristics)
- State v. Mantich, 287 Neb. 320 (2014) (Nebraska application of Miller and retroactivity on collateral review)
- State v. Garza, 295 Neb. 434 (2016) (rejecting requirement of specific formal factfinding when parole remains possible)
- State v. Smith, 295 Neb. 957 (2017) (parole eligibility and life expectancy discussion; "meaningful opportunity" analysis)