State v. Riley
140 Conn. App. 1
Conn. App. Ct.2013Background
- Ackeem Riley was 17 at the time of the Garden Street shootings and later convicted of murder, two counts of attempted murder, two counts of first-degree assault, and conspiracy to commit murder; he was sentenced to 100 years’ imprisonment in Connecticut.
- The Connecticut trial court had broad discretion within statutory ranges and considered the presentence investigation report and mitigation evidence; it concluded rehabilitation was unlikely and imposed a lengthy term.
- Miller v. Alabama (2012) held that mandatory life without parole for juveniles is unconstitutional and that individualized consideration of youth is required; it did not necessarily mandate a second-look remand in every discretionary case.
- This case proceeded under Miller’s framework without a mandatory life-without-parole sentence; the state argued Miller’s rule was limited to mandatory schemes, while Riley argued for a remand to explicitly account for youth on the record.
- The Connecticut Supreme Court affirmed the sentence, holding the current discretionary process already accounts for youth and that Miller does not require a rigid, on-the-record recitation of youth-specific factors in every case.
- The court noted Miller’s emphasis on individualized sentencing and stated the present procedure, including review of the presentence report and opportunity to present mitigation, complies with the Eighth Amendment.
- The case is tied to Graham v. Florida and Roper v. Simmons’s framework for juveniles, and the court found no constitutional error in this case’s sentencing given the record and discretionary reasoning.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miller requires remand for explicit on-the-record youth consideration | Riley argues Miller demands a resentencing with a documented youth-focused analysis | State contends Miller targets only mandatory-life schemes and allows discretionary analysis | No remand required; current discretionary process suffices |
| Whether Connecticut’s sentencing scheme complies with Miller and Graham | Riley asserts youth factors must be explicitly weighed | Court may consider youth through presentence report and discretionary reasoning | Scheme complies with Miller and Graham; no categorical violation found |
| Whether Miller’s language about “uncommon” use of LWOP applies to this homicide case | Miller implies rare use of LWOP for juveniles after considering youth | Discretion allows substantial tailoring; no automatic LWOP | Court’s sentence remains within discretionary bounds and is constitutionally permissible |
Key Cases Cited
- Miller v. Alabama, 132 S. Ct. 2455 (U.S. 2012) (overruled mandatory LWOP for juveniles; requires individualized consideration of youth)
- Graham v. Florida, 560 U.S. 48 (U.S. 2010) (categorically barred LWOP for nonhomicide juveniles; guaranteed meaningful opportunity to be heard for release or modification)
- Roper v. Simmons, 543 U.S. 551 (U.S. 2005) (death penalty for juveniles unconstitutional; youth are less culpable and more capable of change)