State v. Lebeau, 2014 UT 39

LeBeau was convicted of aggravated kidnapping, aggravated assault, and cruelty to an animal following a February 2009 domestic dispute.
The district court sentenced LeBeau to life without parole (LWOP) for aggravated kidnapping, plus other lesser terms, to run consecutively.
The trial court treated LWOP as presumptive under Utah's 76-5-302(8)(b), then weighed aggravating and mitigating factors to possibly reduce the sentence.
The court identified two aggravators and rejected several mitigators, including provocation, work history, and family ties, and thus imposed LWOP.
The Court of Appeals affirmed; certiorari was granted to determine if the LWOP sentence properly complied with the interests-of-justice standard in 76-5-802(4).
On review, the Utah Supreme Court reversed LWOP and remanded for new sentencing, holding the district court erred by applying an improper interests-of-justice analysis and by relying solely on Sentencing Commission guidelines.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did district court properly apply interests-of-justice analysis before LWOP?	LeBeau: district court failed to engage in proper interests-of-justice analysis before LWOP.	State: LWOP permissible with interests-of-justice analysis considered under statute.	Not properly conducted; remand for correct analysis.
Is interests-of-justice equivalent to weighing aggravators/mitigators?	LeBeau: it requires more than the Sentencing Commission factors.	State: the factors align with a balancing of aggravating and mitigating circumstances.	No; requires broader considerations beyond Swenge factors.
What constitutes the proper proportionality/rehabilitation factors for interests-of-justice?	LeBeau: proportionality and rehabilitation must be weighed.	State: district court may consider rehabilitation within discretion.	Court must include proportionality and rehabilitation in analysis.
Did the district court properly evaluate LeBeau's mitigating factors (provocation, history, employment, family)?	LeBeau: court erred in evaluating mitigating factors under proper standards.	State: court can weigh these factors within discretion, within statute.	Remand to reassess mitigating factors under correct standards.

State v. Lebeau, 286 P.3d 1 (Utah App. 2012) (interests-of-justice framework relevant to aggravated kidnapping)
Solem v. Helm, 463 U.S. 277 (U.S. (1983)) (proportionality factors guiding review of harsh penalties)
Gardner v. State, 947 P.2d 630 (Utah 1997) (death-penalty proportionality guidance in Utah context)
Harmelin v. Michigan, 501 U.S. 957 (U.S. (1991)) (discussion of proportionality and harsh penalties)
State v. Lipsky, 608 P.2d 1241 (Utah 1980) (pre-sentence information and notice requirements)
State v. Smith, 909 P.2d 236 (Utah 1995) (board parole consideration and indeterminate sentencing rationale)
State v. Barrett, 127 P.3d 682 (Utah 2005) (statutory interpretive framework for sentencing discretion)