State v. Randles
235 Ariz. 547
| Ariz. Ct. App. | 2014Background
- In Sept. 2011, 17-year-old Marco Keon Randles beat a victim to death with a brick; he was charged with and convicted of first-degree premeditated murder.
- At sentencing the trial court imposed life imprisonment with no possibility of release until serving 25 years under A.R.S. § 13-751.
- At the time of sentencing Arizona had abolished parole for offenses committed on or after Jan. 1, 1994, leaving commutation as the only executive-release mechanism.
- Randles argued his sentence violated Miller v. Alabama because it amounted to a de facto life-without-parole sentence for a juvenile.
- At trial the court excluded defense expert testimony about alcohol’s effects (allowing testimony about cocaine effects), and later ordered Randles to pay DNA testing costs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constitutionality of juvenile life sentence under A.R.S. § 13-751 | State: sentence complied with statute because offender eligible for parole after 25 years under § 13-751 | Randles: sentence unconstitutional under Miller because Arizona effectively abolished parole, leaving only commutation and thus no meaningful parole opportunity | Court: After legislature enacted A.R.S. § 13-716/H.B. 2593 (making juvenile life sentences parole-eligible regardless of commit date), sentence is modified to reflect parole eligibility; Randles’ Miller claim is moot and sentence affirmed as modified |
| Exclusion of expert testimony on alcohol effects | State: effects of alcohol are within common knowledge; expert testimony inadmissible under Plew | Randles: expert toxicologist’s testimony on alcohol would support self-defense by showing victim’s aggression | Court: Trial court did not abuse discretion; alcohol effects are generally within jurors’ common knowledge and sufficient evidence (BAC, pathologist testimony, cocaine-effects testimony) was admitted to support self-defense |
| Order requiring defendant to pay for DNA testing | State: statute authorizes fee | Randles: defendant should not be required to pay | Court: Vacated DNA-cost order consistent with State v. Reyes (A.R.S. § 13-610 does not require convicted defendant to pay testing costs) |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (Eighth Amendment bars mandatory life-without-parole for juveniles)
- Graham v. Florida, 560 U.S. 48 (2010) (commutation-only schemes do not provide a meaningful opportunity for release for juveniles)
- Solem v. Helm, 463 U.S. 277 (1983) (release only by commutation does not constitute a meaningful opportunity for release)
- State v. Plew, 155 Ariz. 44 (1987) (general effects of alcohol are within common knowledge; expert testimony generally unnecessary)
- State v. Salazar, 173 Ariz. 399 (1992) (same principle: jury can assess alcohol’s general effects without expert testimony)
- State v. Reyes, 232 Ariz. 468 (2013) (A.R.S. § 13-610 does not require a convicted defendant to pay for DNA testing)