Wilson v. State, 2017 Ark. 217

Defendant Detric Deshun Wilson was convicted by a jury of aggravated robbery and multiple related offenses; the circuit court sentenced him to life imprisonment under Arkansas’s habitual-offender statute for a Class Y violent felony with two prior violent felonies.
At trial, store employees testified that before the store opened Wilson was cutting jewelry-case locks, reached into a counter with a bag, and threatened employees with a pistol when confronted, causing them to withdraw and cease pursuit as he fled with a sack.
Wilson moved for directed verdicts on aggravated robbery and two robbery counts, arguing insufficient evidence that his threats were made to commit theft or to resist apprehension immediately after theft.
The State argued the threats were made to resist apprehension immediately after committing the theft, and jurors could infer intent from the circumstances.
At sentencing the State proved two prior convictions from 1993 for conspiracy to commit aggravated robbery, committed when Wilson was a juvenile (15–16) but tried and convicted in criminal court as an adult.
Wilson challenged the constitutionality of using those juvenile-aged convictions to impose an automatic life sentence, invoking Miller/Graham/Roper and Arkansas’s cruel-or-unusual-punishment clause.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for aggravated robbery and two robbery counts (directed-verdict challenge)	Evidence showed threats and conduct supporting robbery/aggravated robbery; intent can be inferred — State	Threats were not made to effectuate theft or to resist apprehension immediately after theft, so evidence insufficient	Court held there was substantial evidence to infer the threats were intended to resist apprehension immediately after theft; directed-verdict motions properly denied
Constitutionality of using prior juvenile-aged convictions to enhance sentence to mandatory life under habitual-offender statute	Wilson: Using convictions for crimes he committed as a juvenile to trigger mandatory life violates Eighth Amendment and Ark. Const. art. 2 § 9 (Miller and related precedents require youth be considered)	State: Prior convictions were adult criminal convictions (he was convicted in criminal court), and enhancement punishes conduct as an adult with knowledge of prior record; Miller’s concerns do not apply	Court held a conviction imposed on a juvenile sentenced as an adult may be used for habitual-offender enhancement; life sentence affirmed

Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life without parole for juveniles violates Eighth Amendment because it precludes consideration of youth)
Graham v. Florida, 560 U.S. 48 (2010) (Eighth Amendment prohibits life without parole for juvenile nonhomicide offenders)
Roper v. Simmons, 543 U.S. 551 (2005) (death penalty unconstitutional for crimes committed under age 18)
Watson v. State, 358 Ark. 212 (2004) (intent and circumstantial inference principles in Arkansas criminal cases)
Vanesch v. State, 343 Ark. 381 (2001) (juvenile-delinquency adjudication is not a felony conviction for enhancement purposes)
Dolphus v. State, 248 Ark. 799 (1970) (habitual-criminal sentencing is not a second punishment for prior offenses)