Wyatt L. Bear Cloud
2014 WY 113
| Wyo. | 2014Background
- Bear Cloud, age 16 at offense, participated in burglary and murder of Robert Ernst.
- He pled guilty to first-degree murder, aggravated burglary, and conspiracy to commit aggravated burglary.
- Wyoming district court sentenced: life for murder, 20–25 years for conspiracy, 20–25 years for aggravated burglary; counts to run in certain configurations.
- On remand from Miller v. Alabama, court conducted Miller-factor analysis and prepared a new sentencing plan.
- Wyoming legislature amended parole rules for juvenile murderers in 2013, allowing parole after 25 years.
- Court remanded to consider entire sentencing package and whether aggregate sentence functions as de facto life without parole.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether aggregate consecutive sentence amounts to de facto life without parole | Bear Cloud argues Miller requires individualized sentencing for juveniles. | Wyoming contends Miller does not invalidate aggregate life-equivalent sentences. | Remanded to weigh entire sentencing package with Miller factors. |
| Whether mandatory identical sentencing for accomplices in felony murder violates Eighth Amendment for juveniles | Bear Cloud contends equity with shooter status is unconstitutional under Miller. | Wyoming argues Miller does not extend to all mandatory accomplice sentences. | Court declines broad extension; addresses Miller limits on a case-by-case basis. |
| Whether 20–25 year sentence for aggravated burglary is grossly disproportionate | Bear Cloud asserts lengthy term violates proportionality for youth. | Wyoming argues sentencing must consider entire package; no standalone ruling. | Not addressed on remand; will be reconsidered with Miller hearing and entire package. |
Key Cases Cited
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (mandatory life without parole for juveniles violates Eighth Amendment; requires individualized sentencing)
- Graham v. Florida, 560 U.S. 48 (2010) (life without parole not required for juvenile non-homicide offenders; meaningful opportunity for release)
- Roper v. Simmons, 543 U.S. 551 (2005) (juveniles have diminished culpability; age 18 as line for death penalty)
- Thompson v. Oklahoma, 487 U.S. 815 (1988) (juvenile execution prohibited; evolving standards of decency)
- Enmund v. Florida, 458 U.S. 782 (1982) (accomplice liability limits for death penalty)
- Tison v. Arizona, 481 U.S. 137 (1987) (significant participation required for harsh penalties on accomplices)
- Pepper v. United States, 131 S. Ct. 1229 (2011) (law-of-the-case doctrine on remand; complete sentencing package review)