Vincent Young v. State of Mississippi
245 So. 3d 510
| Miss. Ct. App. | 2017Background
- Vincent Young pled guilty in 1990 to armed robbery and accepted a negotiated life sentence to avoid prosecution as a violent habitual offender (which could have meant life without parole).
- The State dropped an aggravated-assault count and agreed not to pursue habitual-offender enhancement in exchange for Young’s acceptance of life with parole eligibility.
- Decades later Young filed a post-conviction-relief (PCR) motion arguing his life sentence was illegal under the then-prevailing interpretation that only a jury could impose life for armed robbery.
- The circuit court dismissed the PCR as time-barred and on the merits given the Mississippi Supreme Court’s later decision in Bester v. State, which held that statutory language permitting the court to impose "any term" includes life.
- On appeal Young conceded Bester controls but argued applying Bester to his case violated the Ex Post Facto Clauses; the Court of Appeals affirmed.
Issues
| Issue | Plaintiff's Argument (Young) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Legality of life sentence given statute wording | At time of sentencing precedent required a jury to fix life; judge-only life was illegal | Bester now controls: "any term" includes life, so sentence is legal | Court: sentence legal under Bester; affirmed |
| Waiver via plea bargain | Even if statute later interpreted to allow judge-imposed life, Young can challenge illegality now | Young voluntarily negotiated and accepted the life sentence to avoid harsher habitual-offender exposure; he waived challenge | Court: Young waived right to challenge the sentence by pleading and accepting the negotiated life term |
| Retroactive application — Ex Post Facto | Applying Bester to him makes punishment more onerous after the crime — unconstitutional | Ex Post Facto prohibition applies to statutes, not judicial decisions; Bester is judicial and not an ex post facto violation | Court: Ex Post Facto claim fails; judicial decisions are not subject to Ex Post Facto Clause |
| Retroactivity under Due Process (procedural) | (Argued but not developed on appeal) | State: issue not properly briefed; waiver | Court: Due process retroactivity is the correct framework but Young failed to brief/argue it; issue waived on appeal |
Key Cases Cited
- Bester v. State, 188 So.3d 526 (Miss. 2016) (held that statutory language authorizing the court to fix "any term" includes life imprisonment)
- Stewart v. State, 372 So.2d 257 (Miss. 1979) (prior interpretation applied to armed robbery that judge could not impose life unless jury fixed it)
- Lee v. State, 322 So.2d 751 (Miss. 1975) (forcible-rape precedent underlying the prior construction of "any term")
- Rogers v. Tennessee, 532 U.S. 451 (2001) (judicial decisions are generally not subject to Ex Post Facto challenges; due process governs retroactive effect)
- Collins v. Youngblood, 497 U.S. 37 (1990) (Ex Post Facto Clause forbids statutes that make punishment more burdensome after commission)
- Beazell v. Ohio, 269 U.S. 167 (1925) (early Ex Post Facto principle quoted in Collins)
- Jackson v. State, 551 So.2d 132 (Miss. 1989) (noting sentencing is generally within circuit court discretion, subject to statute and constitutional limits)