Vickers v. State
117 A.3d 516
Del.2015Background
- Victim was shot during a home invasion; Vickers was arrested, tried, and convicted of multiple felonies including attempted first‑degree robbery, home invasion, second‑degree assault, conspiracy, and three counts of felony firearm possession.
- The State moved to sentence Vickers as a habitual offender under 11 Del. C. § 4214(b); Superior Court granted the motion and imposed multiple life sentences and additional terms.
- Vickers has three qualifying violent felony convictions: Arson (1995), Robbery (1998), and the current convictions; he was tried and sentenced as an adult for the 1995 arson despite being a juvenile at the time of that offense.
- Vickers conceded the conviction history and that statutory elements for habitual status were met, but appealed solely arguing the 1995 juvenile conviction should not count because recent U.S. Supreme Court juvenile‑culpability decisions require considering youth at sentencing.
- State and Superior Court treated the juvenile conviction as permissible to enhance an adult’s sentence, arguing the juvenile‑leniency cases apply to juvenile sentencing, not to use of juvenile convictions in adult recidivist enhancements.
- The Delaware Supreme Court reviewed the constitutional question de novo and affirmed the habitual offender sentence.
Issues
| Issue | Vickers' Argument | State's Argument | Held |
|---|---|---|---|
| Whether a felony conviction obtained while the defendant was a juvenile may be counted toward habitual‑offender enhancement for an adult sentence | Vickers: Recent SCOTUS decisions (Roper, Graham, Miller) recognize diminished juvenile culpability; due process/Eighth Amendment require considering youth and therefore juvenile convictions should not be used to mandate life as a habitual offender | State: Those SCOTUS cases limit severe juvenile sentences; they do not prohibit using juvenile convictions to enhance an adult’s sentence; Vickers was sentenced as an adult for adult crimes | Court: Juvenile convictions may be counted for adult habitual‑offender enhancement; SCOTUS juvenile‑leniency cases do not bar such use |
Key Cases Cited
- Roper v. Simmons, 543 U.S. 551 (2005) (juveniles cannot be executed; recognizes diminished culpability of youth)
- Graham v. Florida, 560 U.S. 48 (2010) (life without parole for nonhomicide juvenile offenders unconstitutional)
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life without parole for juvenile homicide offenders unconstitutional)
- Fletcher v. State, 409 A.2d 1254 (Del. 1979) (Delaware precedent regarding admissibility of juvenile convictions for certain purposes)