State v. Williams-Bey
144 A.3d 467
| Conn. App. Ct. | 2016Background
- In 1997 Tauren Williams-Bey (age 16 at the time) participated in a murder; he pleaded guilty to murder as an accessory and was sentenced in 2000 to 35 years imprisonment (parole ineligible at sentencing under the law then in effect).
- Williams-Bey filed a motion to correct an illegal sentence (asserting Eighth Amendment violations under Graham and Miller) in 2013; the trial court dismissed for lack of jurisdiction and held Miller/Graham inapplicable to his sentence.
- Since the motion, Connecticut enacted Public Act 15-84 (effective Oct. 1, 2015), codified in part at Conn. Gen. Stat. § 54-125a(f), making many juvenile offenders parole-eligible (with statutory criteria requiring the parole board to consider youth-related mitigating factors and to provide counsel for indigent juveniles).
- The U.S. Supreme Court decided Montgomery v. Louisiana (2016), holding Miller retroactive and stating that states may remedy Miller violations by making juvenile homicide offenders parole-eligible rather than resentencing in every case.
- The Appellate Court concluded the trial court erred to dismiss for lack of jurisdiction but ultimately held Williams-Bey’s federal and state constitutional claims fail because parole eligibility under § 54-125a(f), in light of Montgomery, provides a constitutionally adequate remedy.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Williams-Bey) | Held |
|---|---|---|---|
| Jurisdiction to hear a motion to correct an illegal sentence | Trial court properly lacked jurisdiction because Miller/Graham did not clearly apply to lengthy term-of-years sentences at time of sentencing | Motion to correct challenged the manner of sentencing (failure to consider Miller factors) and was properly before the court under Practice Book §43-22 | Appellate Court: trial court erred to dismiss; it had jurisdiction and should have denied (not dismissed) the motion on the merits |
| Whether 35-year term (parole-ineligible at sentencing) violated the Eighth Amendment per Miller | Miller applies only to mandatory LWOP; therefore defendant’s sentence does not implicate Miller | Miller requires individualized consideration of youth; Williams-Bey contends he is entitled to resentencing because that consideration did not occur | Court: assuming arguendo Miller applied, Montgomery and §54-125a(f) make parole eligibility a constitutionally adequate remedy; therefore no Eighth Amendment violation requiring resentencing |
| Whether parole eligibility per §54-125a(f) is a sufficient remedy under federal law (Montgomery) | Parole eligibility satisfies Montgomery’s remedial option and provides individualized consideration at parole hearings | Argued Montgomery’s statements about parole were dicta and conflict with Connecticut Supreme Court precedents (Riley, Casiano) — thus resentencing required | Court: Montgomery’s remedial guidance is authoritative (not mere dicta); combined with §54-125a(f) it provides a constitutionally adequate remedy under the federal Constitution |
| Whether the Connecticut Constitution requires resentencing (beyond federal minimum) | State can provide remedies via parole; legislature intended §54-125a(f) to respond to Miller/Graham | Williams-Bey urges Connecticut constitution affords broader protection and requires resentencing like Riley/Casiano remands | Court: applying Geisler factors, parole eligibility under §54-125a(f) is an adequate remedy under Connecticut Constitution for those who become parole eligible under that statute; resentencing not required here |
Key Cases Cited
- Miller v. Alabama, 132 S. Ct. 2455 (U.S. 2012) (mandatory life without parole for juvenile homicide offenders violates the Eighth Amendment and requires individualized consideration of youth)
- Graham v. Florida, 560 U.S. 48 (U.S. 2010) (juvenile nonhomicide offenders cannot be sentenced to life without parole; they must have a meaningful opportunity for release)
- Montgomery v. Louisiana, 136 S. Ct. 718 (U.S. 2016) (Miller applies retroactively; states may remedy Miller violations by making offenders parole-eligible rather than resentencing in every case)
- State v. Riley, 315 Conn. 637 (Conn. 2015) (Connecticut Supreme Court applying Miller/Graham to discretionary and de facto life sentences and remanding for resentencing)
- Casiano v. Commissioner of Correction, 317 Conn. 52 (Conn. 2015) (Connecticut Supreme Court applying Miller retroactively on collateral review and remanding for resentencing)