836 S.E.2d 348
S.C.2019Background
- On June 11, 2014, then-17-year-old Terrell Smith fatally stabbed his friend and then attacked the victim's father; the victim died shortly thereafter.
- Smith was convicted of murder, attempted murder, and a weapons offense; he received concurrent terms of 35 years (murder) and 30 years (attempted murder), plus a concurrent 5-year weapons sentence.
- South Carolina law (S.C. Code § 16-3-20(A)) imposes a 30-year mandatory minimum for murder, applicable to juveniles and adults alike.
- Because Smith was a juvenile facing possible life, the trial court held an Aiken hearing (an individualized mitigation hearing addressing Miller's five youth factors); mitigation evidence was presented but the court denied Smith's motion to declare the statute unconstitutional as applied to juveniles.
- Smith appealed, arguing the mandatory minimum violated the Eighth Amendment as informed by Roper/Graham/Miller by preventing adequate consideration of juvenile characteristics; the Supreme Court of South Carolina affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a statutory mandatory minimum sentence for murder violates the Eighth Amendment as applied to juvenile offenders | Smith: Mandatory minimums treat juveniles and adults the same, nullifying individualized mitigation informed by Miller's youth factors | State: Miller (and related cases) did not abolish mandatory minimums; legislature may set minimums; Aiken hearing provided individualized consideration | Court: Statute constitutional as applied; Miller does not directly prohibit mandatory minimums; affirmed convictions and sentences |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (holding mandatory LWOP for juvenile homicide offenders violates the Eighth Amendment)
- Graham v. Florida, 560 U.S. 48 (2010) (Eighth Amendment prohibits LWOP for nonhomicide juvenile offenders)
- Roper v. Simmons, 543 U.S. 551 (2005) (death penalty unconstitutional for crimes committed while under 18)
- Aiken v. Byars, 410 S.C. 534 (S.C. 2014) (plurality opinion establishing procedure for individualized sentencing review of juveniles facing life)
- State v. Slocumb, 426 S.C. 297 (S.C. 2019) (state court narrowly interpreting Miller and declining to extend its holdings)
- Burrell v. State, 207 A.3d 137 (Del. 2019) (holding Miller did not prohibit mandatory minimums for juveniles under the federal Eighth Amendment)