Toca v. Louisiana

Summarized by:

  • Court: U.S. Supreme Court Certiorari Granted
  • Area(s) of Law: Sentencing
  • Date Filed: December 12, 2014
  • Case #: 14-6381
  • Judge(s)/Court Below: Court Below: 141 So. 3d 265 (2014)
  • Full Text Opinion

(1) Whether the rule announced in Miller v. Alabama that states that a mandatory life sentence without parole for those under 18 years of age violates the 8th Amendment's prohibition on cruel and unusual punishment applies retroactively, and (2) Whether a federal question is raised by a claim that a state court failed to find a Teague exception.

Petitioner was 17 years old when he was arrested in 1984 for the accidental shooting of his best friend. Under Louisiana’s mandatory sentencing law, Petitioner was sentenced to life without the option of parole, probation, or suspension of sentence. He alleges that he was sentenced to die in prison with no consideration of his youth at the time of the incident. He also suggests that the Louisiana courts did not consider the circumstances or other mitigating facts when setting the sentence – including that the victim’s family does not want him in prison. Petitioner argues that because he was under 18 at the time of the crime, the Louisiana Supreme Court has sentenced him to cruel and unusual punishment, in violation of the 8th Amendment and in contradiction to the previous Supreme Court case of Miller v. Alabama, 132 S. Ct. 2455 (2012).

Since the Miller decision, courts have been divided on whether this decision applies retroactively. To consider whether a decision applies retroactively, courts may utilize a framework established in Teague v. Lane, 489 U.S. 288 (1989), which held that new rules that place “certain kinds of primary, private individual conduct beyond the power of the criminal law-making authority to proscribe” apply retroactively to certain cases. Here, the district court held that Miller applied retroactively to this case, and granted Petitioner’s Motion to Correct an Illegal Sentence. However, the Louisiana Supreme Court reversed that decision. Petitioner appealed to the Supreme Court for clarification as to whether the Miller decision applies retroactively.

The Supreme Court will address two issues: (1) whether the rule announced in Miller that states that a mandatory life sentence without parole for those under 18 years of age violates the 8th amendment's prohibition on cruel and unusual punishment applies retroactively, and (2) whether a federal question is raised by a claim that a state court failed to find a Teague exception.

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