Virginia v. LeBlanc
137 S. Ct. 1726
| SCOTUS | 2017Background
- In 1999 Dennis LeBlanc, age 16, raped a 62‑year‑old woman and in 2003 was sentenced in Virginia to life imprisonment.
- In 2010 this Court decided Graham v. Florida, ruling juveniles convicted of nonhomicide offenses must be given a "meaningful opportunity" for release based on demonstrated maturity and rehabilitation.
- Virginia abolished traditional parole and created a geriatric release statute permitting conditional release for offenders meeting age-and-time-served thresholds (age 60/10 years or 65/5 years) with Parole Board review using normal parole factors.
- LeBlanc challenged his life sentence under Graham; Virginia trial court denied relief relying on Angel v. Commonwealth, where the Virginia Supreme Court held the geriatric release program satisfied Graham.
- A federal district court granted habeas relief; the Fourth Circuit affirmed (panel majority) holding the state court unreasonably applied Graham; Virginia sought certiorari.
- The Supreme Court (per curiam) reversed the Fourth Circuit, holding the state court’s application of Graham was not objectively unreasonable under AEDPA.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Virginia trial court unreasonably applied Graham under AEDPA | LeBlanc: geriatric release fails to provide a meaningful opportunity because Board discretion and long wait (decades) deny realistic parole prospects | Virginia: geriatric release uses normal parole factors (including rehabilitation/maturity) and thus satisfies Graham; state courts entitled to AEDPA deference | Held: state court decision was not an objectively unreasonable application of Graham; AEDPA deference required reversal of Fourth Circuit |
| Whether Graham categorically bars geriatric-release schemes as compliant mechanisms | LeBlanc: scheme functionally leaves juveniles without a real opportunity for release | Virginia: Graham left States latitude to design mechanisms; Angel interpreted statute to require consideration of rehabilitation | Held: Question unresolved on merits; reasonable arguments both ways — federal habeas cannot resolve under AEDPA |
| Whether federal courts should override state-court interpretation of state parole law | LeBlanc: federal courts may review whether state procedure provides meaningful opportunity under Eighth Amendment | Virginia: federal habeas review limited and must defer to reasonable state-court interpretations of federal law under AEDPA | Held: AEDPA requires deference; Fourth Circuit failed to accord it and erred |
| Remedy on habeas when state court applied Graham differently than federal court panel | LeBlanc: grant relief and vacate sentence | Virginia: deny relief; uphold state-court ruling | Held: Habeas relief improper because state ruling was not beyond fair‑minded disagreement; judgment reversed |
Key Cases Cited
- Graham v. Florida, 560 U.S. 48 (Eighth Amendment forbids life without parole for juvenile nonhomicide offenders without meaningful opportunity for release)
- Angel v. Commonwealth, 281 Va. 248 (Va. 2011) (Virginia Supreme Court held geriatric release statute satisfies Graham)
- LeBlanc v. Mathena, 841 F.3d 256 (4th Cir. 2016) (Fourth Circuit panel held state court unreasonably applied Graham)
- Harrington v. Richter, 562 U.S. 86 (AEDPA’s standard is highly deferential; federal courts cannot grant relief for mere error)
- White v. Woodall, 572 U.S. _ (federal courts must find absence of any fair‑minded disagreement to overturn state decision under AEDPA)
- Woods v. Donald, 575 U.S. _ (state-court error must be objectively unreasonable, not merely wrong)
- Marshall v. Rodgers, 569 U.S. _ (per curiam) (AEDPA limits federal habeas review of unsettled questions on direct merits)