State v. Williams, Minn.S.Ct., 5/6/2015. Twenty years ago, a jury convicted Mr. Williams of two counts of first degree murder, one count of attempted first degree murder, and one count of burglary. Mr. Williams was sixteen when he committed these offenses. The trial court imposed the presumptive sentence of life with the possibility of release after thirty years for the two first degree murder convictions. The trial court then imposed a discretionary consecutive sentence of two hundred forty months on the attempted murder conviction, and a discretionary consecutive sentence of eighteen months on the burglary. The resulting aggregate sentence was seventy-four years in prison. That would make Mr. Williams roughly ninety years old when he becomes eligible for release.
Mr. Williams filed this Rule 27.03 motion to correct sentence. He said that the rule of Miller v. Alabama, should apply to Minnesota’s statutory provisions that landed him in prison until age ninety at least, there being no guarantee that he’d be released then. He said that the combination of mandatory imposition of two life imprisonment sentences with the possibility of release plus the (discretionary) consecutive sentences are the functional equivalent of life imprisonment without the possibility of release. Justice Wright, for the entire court, ignores that assertion and, instead, looks at the component parts of this aggregate sentence. It wasn’t especially difficult to then conclude that each of the component parts of the sentence were neither cruel nor unusual punishment. Under prior opinions, the two life sentences with possibility of release do not amount to a “death sentence” when applied to a juvenile and thus don’t constitute cruel and unusual punishment under the Eighth Amendment. State v. Ouk, 847 N.W.2d 248 (Minn. 2014). As to the discretionary consecutive sentences, well, Miller just doesn’t apply to a non-mandatory sentence. Never mind about the functional equivalence argument.
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