State v. Miller, 2021 Ohio 3381

Appellant Tyler R. Miller was 16 at the time he stabbed a defenseless victim multiple times and was indicted for aggravated murder after transfer from juvenile court.
Miller initially pleaded not guilty by reason of insanity; the CDTC evaluation found he was not legally insane and the court admitted that report.
After the insanity plea was denied, Miller pleaded guilty to aggravated murder and a presentence investigation was ordered.
At sentencing the trial court considered Miller’s age as a mitigating factor but found him irreparably corrupt based on lack of remorse, homicidal ideation (including fantasies of becoming a serial killer), prior animal-killing behavior, and the premeditated, brutal nature of the crime.
The court sentenced Miller to life imprisonment without parole and assessed prosecution costs; Miller appealed, raising ineffective-assistance and Eighth Amendment (cruel and unusual punishment) arguments.
The Sixth District affirmed: pre-plea ineffective-assistance claims were waived; counsel’s failure to request a costs waiver at sentencing was a permissible trial strategy; and the LWOP sentence complied with governing juvenile-sentencing precedent and the court’s discretionary duties.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Ineffective assistance of counsel	Miller: counsel was deficient for not filing motions, not challenging juvenile bindover, and not requesting a waiver of prosecution costs at sentencing.	State: pre-plea complaints are waived by a voluntary guilty plea; decision not to seek a costs waiver at sentencing was trial strategy.	Pre-plea claims waived; counsel was not ineffective regarding costs—strategy to emphasize youth and rehabilitation prospects justified timing of waiver request.
2. Constitutionality/abuse of discretion of LWOP for juvenile	Miller: court erred in finding him "irreparably corrupt" and failed to properly weigh youth and other mitigating factors; LWOP is cruel and unusual for juveniles except in rare cases.	State: sentencing was discretionary, court expressly considered Miller’s age, and record supports finding of irreparable corruption and LWOP.	Affirmed: court considered youth, explained reasons, found irreparable corruption on the record; LWOP discretionary and permissible under Ohio and U.S. precedent.

Strickland v. Washington, 466 U.S. 668 (1984) (standard for ineffective assistance of counsel).
State v. Bradley, 42 Ohio St.3d 136 (1989) (deferential review of counsel performance).
Roper v. Simmons, 543 U.S. 551 (2005) (juvenile death penalty unconstitutional).
Graham v. Florida, 560 U.S. 48 (2010) (LWOP for nonhomicide juvenile offenses unconstitutional).
Miller v. Alabama, 567 U.S. 460 (2012) (mandatory LWOP for juveniles unconstitutional; only rare juveniles may receive LWOP).
Montgomery v. Louisiana, 577 U.S. 190 (2016) (Miller applies retroactively; juvenile LWOP reserved for those reflecting permanent incorrigibility).
Jones v. Mississippi, 141 S. Ct. 1307 (2021) (sentencer need not make a separate factual finding of permanent incorrigibility to impose discretionary LWOP).
State v. Long, 138 Ohio St.3d 478 (2014) (Ohio requires consideration of youth as a mitigating factor before imposing juvenile LWOP).
State v. Davis, 159 Ohio St.3d 31 (2020) (trial courts must impose prosecution costs but retain jurisdiction to waive or modify them later).