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State of Connecticut v. Ackeem Riley

Posted on by John J. Ghidini III

In this case, the Connecticut Supreme Court held that “the dictates set forth in Miller may be violated even when the sentencing authority has discretion to impose a lesser sentence than life without parole it it fails to give due weight to evidence that Miller deemed constitutionally significant before determining that such a severe punishment is appropriate...the record must reflect that the trial court has considered and given due mitigating weight to these factors in determining a proportionate punishment...”

This case was decided in light of the holdings in a trilogy of United States Supreme Court cases that drastically altered the legal landscape in terms of sentencing juvenile offenders. First, in Roper v. Simmons, the United States Supreme Court barred capital punishment for all juvenile offenders. This holding was based upon the 8th Amendments bar against cruel and unusual punishment. Second, in Graham v. Florida, the Court barred life sentences of life without the possibility of parole for juvenile non homicide offenders and Third, in Miller v. Alabama, the Court held mandatory sentencing schemes that impose life imprisonment without parole on juvenile homicide offenders, thus precluding consideration of the offender's youth as mitigating against such a severe punishment, violates the principle of proportionate punishment under the Eight Amendment.

In the Riley case the Connecticut Supreme court held that the sentencing court should have reviewed mitigating factors prior to sentencing Mr. Riley.  Mr. Riley committed both homicide and non homicide offenses and should have received the protections of the law as announced by the United States Supreme Court in Miller.