State v. Long
138 Ohio St. 3d 478
| Ohio | 2014Background
- Long was 17 when two shootings occurred leading to two counts of aggravated murder and multiple other charges; codefendants Whipple and Clark were adults at the time.
- Following a joint trial, Long and codefendants were convicted on numerous counts and sentenced to consecutive life terms without parole for aggravated murder plus additional terms.
- Long appealed claiming the trial court failed to separately consider his youth as a mitigating factor and that life without parole for a juvenile constitutes cruel and unusual punishment.
- The First District rejected the Eighth Amendment challenge based on Miller, distinguishing the nonmandatory nature of Ohio’s sentencing scheme; the Ohio Supreme Court ultimately held that youth must be considered as a mitigating factor before a life-without-parole sentence and remanded for resentencing.
- The opinion concludes that Miller requires explicit consideration of youth as a mitigating factor, and that Long’s sentence must be resentenced with that consideration on the record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miller requires separate consideration of youth as a mitigating factor. | Long argues Miller demands explicit youth consideration. | State contends the record shows Miller considerations and Ohio’s discretion. | Yes, remand for resentencing to reflect youth as a mitigating factor. |
| Whether Ohio’s sentencing framework complies with Miller/Graham. | Long contends the trial court failed to apply Miller’s process. | State maintains discretion and no mandatory flaw. | Yes, court must reflect Miller considerations on the record. |
| Whether the lack of explicit mention of Long’s youth invalidates the sentence. | Long asserts the court did not separate or weigh youth. | State argues dobra discretion; explicitness not required. | Remand required to ensure Miller-compliant reasoning. |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (holding mandatory life without parole for juveniles violates Eighth Amendment; court requires individualized sentencing)
- Graham v. Florida, 560 U.S. 48 (2010) (juveniles convicted of nonhomicide offenses cannot be sentenced to LWOP)
- Roper v. Simmons, 543 U.S. 551 (2005) (juveniles are less culpable and protected from executions)
- In re C.P., 131 Ohio St.3d 513 (2012) (Eighth Amendment limitations relevant to Ohio sentencing decisions)
- State v. Jackson, 107 Ohio St.3d 53 (2005) (mitigation and sentencing discretion standards in Ohio)