315 Conn. 637
Conn.2015Background
- Ackeem Riley received a total effective sentence of 100 years for a mass drive-by shooting killing a 16-year-old and injuring two others.
- Sentencing proceeded after a hearing with a presentence investigation report and arguments from counsel; Riley did not testify.
- The sentencing court considered the crime’s nature, victims, family background, prior arrests, and Riley’s youth in fashioning the sentence.
- The sentence is divided 60 years for murder and 20 years for each attempted murder, run consecutively, totaling 100 years.
- Connecticut’s sentencing statute and practice provide individualized sentencing, which the dissent argues Miller v. Alabama already requires for juveniles.
- The majority’s reasoning is challenged as extending Miller beyond its limited scope to discretionary schemes.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miller v. Alabama applies to Connecticut’s discretionary sentencing scheme | Riley: Miller applies only to mandatory life-without-parole, not discretionary schemes | State: Miller applies more broadly to juvenile sentencing considerations (context implied by majority) | Miller does not apply to Connecticut's discretionary scheme |
Key Cases Cited
- Miller v. Alabama, 132 S. Ct. 2455 (U.S. 2012) (mandatory life without parole for juveniles; scope restricted to mandatory schemes)
- Roper v. Simmons, 543 U.S. 551 (U.S. 2005) (execution of juvenile offenders prohibited)
- Graham v. Florida, 560 U.S. 48 (U.S. 2010) (life without parole for nonhomicide juvenile offenses prohibited)