State v. Valencia
239 Ariz. 255
| Ariz. Ct. App. | 2016Background
- Valencia and Healer were juveniles convicted of first-degree murder and sentenced to natural life in prison (no parole).
- Both sought post-conviction relief asserting Miller v. Alabama changed the law and rendered their natural-life sentences unconstitutional for juveniles.
- Trial courts summarily denied relief, finding age had been considered at sentencing and the sentences lawful under then-existing Arizona law.
- This court previously remanded each case to allow proper consideration of Miller-based claims and ordered supplemental briefing after Montgomery was decided.
- The Supreme Court in Montgomery clarified Miller applies retroactively and permits natural-life only for the rare juvenile offender whose crime reflects permanent incorrigibility.
- The Arizona Court of Appeals concluded Montgomery announced a significant change in the law that requires resentencing of Valencia and Healer.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miller/Montgomery constitute a significant change in Arizona law entitling resentencing under Ariz. R. Crim. P. 32.1(g) | Miller bars life without parole for juveniles; Valencia/Healer say Arizona’s scheme failed to account for youth and thus warrants resentencing | State: Miller inapplicable because sentences were discretionary, not mandatory; statutory changes and prior consideration of age suffice | Held: Montgomery/Miller constitute a significant, retroactive change; resentencing is required |
| Whether a sentencing court’s mere consideration of age satisfies Miller/Montgomery | Valencia/Healer: Mere consideration is insufficient; courts must determine whether offender is permanently incorrigible | State: Sentencing courts did consider age and juvenile characteristics at original sentencing | Held: Mere consideration is insufficient; courts must specifically assess whether crimes reflect permanent incorrigibility before imposing natural life |
| Whether Miller only applies to mandatory life-without-parole schemes | Valencia/Healer: Miller proscribes life-without-parole for juveniles generally | State: Miller targeted mandatory schemes; discretionary schemes different | Held: Rule applies regardless of formal discretion; natural life unconstitutional for juveniles except in rare permanent-incorrigibility cases |
| Whether record here supports a finding of permanent incorrigibility | Valencia/Healer: Record does not show permanent incorrigibility | State: Implied that sentencing findings were sufficient | Held: Court found the record did not plainly support that conclusion and remanded for resentencing so parties can present evidence relevant to Montgomery standard |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (Eighth Amendment forbids mandatory life without parole for juveniles; courts must account for youth)
- Montgomery v. Louisiana, 577 U.S. 190 (2016) (Miller rule is substantive and retroactive; natural life permitted only for juveniles whose crimes reflect permanent incorrigibility)
- Teague v. Lane, 489 U.S. 288 (1989) (retroactivity framework for new constitutional rules)
- Thompson v. Oklahoma, 487 U.S. 815 (1988) (juvenile sentencing considerations differ from adults)
- State v. Werderman, 237 Ariz. 342 (App. 2015) (definition of a "significant change in the law")
- State v. Shrum, 220 Ariz. 115 (2009) (examples of transformative legal change)
- State v. Greenway, 170 Ariz. 155 (1991) (sentencing court should consider juvenile maturity, judgment, and role in crime)