State v. Watkins, 2018 Ohio 5137

Watkins was indicted for multiple robberies, kidnappings, sexual offenses, and firearm specifications arising from four incidents in 2011; he was 16 at the time of the crimes and 18 when he pled guilty.
On the morning of trial Watkins pleaded guilty to multiple counts (five aggravated robberies, one robbery, sexual battery, gross sexual imposition, and three firearm specifications); the court informed him his exposure was up to 73.5 years.
Two days before sentencing Watkins filed a presentence motion to withdraw his guilty plea alleging family pressure and misunderstanding; the trial court nonetheless sentenced him to an aggregate 67-year prison term and later denied the withdrawal motion after a hearing.
On initial appeal this court affirmed both denial of the plea-withdrawal motion and the sentence; the Ohio Supreme Court reversed and remanded for application of State v. Moore.
On remand, the Tenth District reexamined Watkins’ Eighth Amendment challenge under Moore/Graham and concluded that Watkins would be eligible for judicial release after serving 33.5 years (age ~50), which provided a “meaningful opportunity” for release and therefore did not constitute a functional life-without-parole sentence.
The court again affirmed denial of the presentence motion to withdraw the plea (no abuse of discretion) and upheld the 67-year aggregate sentence under the Eighth Amendment.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Watkins)	Held
Whether trial court abused discretion denying presentence motion to withdraw guilty plea	Denial was proper; plea was voluntary and court followed procedure	Plea resulted from family pressure and misunderstanding; should be withdrawn before sentencing	Denial affirmed — no abuse of discretion (court reiterated prior analysis)
Whether 67-year aggregate term violates Eighth Amendment as functional life sentence for juvenile nonhomicide offender	Sentence affords judicial-release eligibility at a meaningful age (50); complies with Moore/Graham	Aggregate term exceeds life expectancy and thus is cruel and unusual under Moore/Graham	Held constitutional — eligibility at ~age 50 provides meaningful opportunity for release and does not violate Eighth Amendment

State v. Moore, 149 Ohio St.3d 557 (Ohio 2016) (aggregate term-of-years that precludes release during juvenile's life expectancy is the functional equivalent of life-without-parole)
Graham v. Florida, 560 U.S. 48 (2010) (life-without-parole for juvenile nonhomicide offenders is unconstitutional; juveniles must have a meaningful opportunity for release)
Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life-without-parole for juveniles convicted of homicide is unconstitutional)
Roper v. Simmons, 543 U.S. 551 (2005) (death penalty unconstitutional for crimes committed under age 18)
Kennedy v. Louisiana, 554 U.S. 407 (2008) (categorical Eighth Amendment limits on punishment for nonhomicide sex offenses)
Atkins v. Virginia, 536 U.S. 304 (2002) (Eighth Amendment prohibits execution of intellectually disabled defendants)