Issue

Eighth Amendment—consecutive life sentences imposed—juvenile defendant—Miller factors

Summary

The Supreme Court upheld defendant's consecutive sentences of life without the possibility of parole, which were imposed after he was convicted of two counts of first-degree murder for killing his parents just before he turned eighteen years old, where the sentences did not violate the Eighth Amendment of the federal Constitution as interpreted by Miller v. Alabama, 567 U.S. 460 (2012) or Art. I, sec. 27 of the North Carolina constitution, which does not provide additional protections for juvenile defendants. The trial court expressly considered evidence in mitigation with regard to each of the factors contained in N.C.G.S. § 15A-1340.19B–a statute that was enacted to address the Miller requirements–including defendant's youth and attendant circumstances, and defendant's capacity to consider the consequences of his actions, and did not abuse its discretion in weighing the evidence and the factors before reaching its sentencing decision.

Summary from the North Carolina Reports digest (official subject index). Read the opinion →