2025 Ark. 41
Ark.2025Background
- Warren Goodrum was convicted of capital murder, abuse of a corpse, and firearm enhancement for a crime committed at age 18.
- The murder involved luring the victim to a wooded area and killing him with both gunshots and stab wounds, later concealing the body.
- The jury returned a guilty verdict, and Goodrum opted for sentencing by the judge (not a jury).
- The death penalty was not sought by the State; under Arkansas law, the mandatory sentence for capital murder is life without parole.
- Goodrum did not object to or raise constitutional challenges to his mandatory sentence during trial or at sentencing.
- On appeal, Goodrum argued for extension of Miller v. Alabama to 18-year-olds and claimed his sentence violated the Eighth Amendment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miller v. Alabama should apply to 18-year-olds | Miller's protections should extend to 18-year-olds | Precedent holds Miller applies to under 18 only | Not preserved on appeal; not addressed |
| Whether mandatory life without parole for 18-year-olds violates the Eighth Amendment | Sentence is unconstitutional without individualized consideration | Sentence complies with Arkansas law; no objection raised | Not preserved on appeal; affirm sentence |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (held that mandatory life without parole for juveniles under 18 violates the Eighth Amendment)
- Stokes v. Payne, 2024 Ark. 56 (Ark. 2024) (declined to extend Miller to crimes committed at 18 or older)
- Gibbs v. Payne, 2023 Ark. 29 (Ark. 2023) (same)
- Benton v. Kelley, 2020 Ark. 237 (Ark. 2020) (same)