Justia U.S. 11th Circuit Court of Appeals Opinion Summaries

A class of incarcerated juvenile offenders in Florida, all sentenced to life in prison with the possibility of parole under a now-defunct sentencing scheme, sued the Commissioners of the Florida Commission on Offender Review. They claimed that the parole system violated the Eighth Amendment's prohibition against cruel and unusual punishment and the Fourteenth Amendment's due process rights. The plaintiffs argued that the parole system did not provide a meaningful opportunity for release based on demonstrated maturity and rehabilitation.The United States District Court for the Middle District of Florida granted summary judgment to the Commissioners, dismissing the plaintiffs' claims. The court found that Florida's parole system did not violate the Eighth Amendment or the Fourteenth Amendment's Due Process Clause. The plaintiffs appealed the decision.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Florida's parole system does not violate the Eighth Amendment for either homicide or non-homicide juvenile offenders. For homicide offenders, the system is not a sham and provides a genuine possibility of parole, satisfying the requirements set forth in Miller v. Alabama. For non-homicide offenders, the system offers a meaningful opportunity for release based on demonstrated maturity and rehabilitation, as required by Graham v. Florida.Regarding the due process claim, the court concluded that the plaintiffs did not have a constitutionally protected liberty interest in parole under either state law or the Eighth Amendment. Therefore, their procedural due process claim failed. The Eleventh Circuit affirmed the district court's grant of summary judgment to the Commissioners. View "Howard v. Coonrod" on Justia Law

The Eleventh Circuit affirmed defendant's sentence of 685 months in prison for multiple armed robbery and carjacking crimes committed while he was a juvenile. The court held that defendant did not assert any valid ground for vacating his convictions where the district court did not err in its suppression rulings; the district court properly dismissed defendant's original indictment without prejudice; defendant's second indictment was timely; and the district court's evidentiary rulings did not warrant reversal. The court also held that the district court did not err in sentencing defendant. In this case, defendant's sentence complied with Graham v. Florida, 560 U.S. 48 (2010), because defendant had some meaningful opportunity to obtain release during his lifetime. Finally, defendant's sentence was not vindictive. View "United States v. Mathurin" on Justia Law

The Eleventh Circuit affirmed defendant's sentence of 685 months in prison for multiple armed robbery and carjacking crimes committed while he was a juvenile. The court held that defendant did not assert any valid ground for vacating his convictions where the district court did not err in its suppression rulings; the district court properly dismissed defendant's original indictment without prejudice; defendant's second indictment was timely; and the district court's evidentiary rulings did not warrant reversal. The court also held that the district court did not err in sentencing defendant. In this case, defendant's sentence complied with Graham v. Florida, 560 U.S. 48 (2010), because defendant had some meaningful opportunity to obtain release during his lifetime. Finally, defendant's sentence was not vindictive. View "United States v. Mathurin" on Justia Law

Defendant was convicted and sentenced to death in 1995 for murder. Because defendant was seventeen years old at the time of the murder, the state court eventually set aside his death sentence and resentenced him to life imprisonment. On appeal, defendant contended that his life without parole sentence was an unconstitutional penalty for him because he was not yet eighteen years old at the time he committed the murder. The court held that it owed 28 U.S.C. 2254(d)(1) deference to the state trial and appellate court decisions that defendant's life without parole sentence, and the procedures under which it was imposed, were not unconstitutional in light of the Roper v. Simmons decision.