Juvenile Law Center

Juvenile and Criminal Justice

Commonwealth of Pennsylvania v. Batts

Juvenile Law Center, in collaboration with the Defender Association of Philadelphia and faculty members at Temple University Beasley School of Law, Boston University School of Law, and the University of San Francisco School of Law, filed an amicus brief on behalf of Qu’eed Batts, who was sentenced to life without the possibility of parole (LWOP) for a homicide he committed at the age of 14. In Pennsylvania, LWOP is a mandatory sentence for anyone convicted of first or second degree murder.

The brief argued that the life without parole sentence violates the United States and Pennsylvania Constitutions as well as international law. In Graham v. Florida, the United States Supreme Court held that a sentence of life without parole imposed on a juvenile convicted of a non-homicide offense was unconstitutional, grounding its decision in developmental and scientific research demonstrating that juveniles possess a greater capacity for rehabilitation, change, and growth than adults, and reasoning that the sentence therefore served no legitimate penological purpose when applied to juveniles. Juvenile Law Center’s brief argued that Graham applied in this case as well, since the reasoning about the differences between juveniles and adults apply regardless of the type of crime at issue.

The brief also argued that the sentence is not in conformity with national and international sentencing trends, as only three other states mandate LWOP sentences for juveniles under the age of fourteen convicted of homicide and the United States is alone in the world in imposing life without parole sentences on juveniles.

Juvenile Law Center argued the case before the Pennsylvania Supreme Court December 1, 2010.

On December 6, 2011, the Pennsylvania Supreme Court ordered a hold placed on the case pending disposition by the U.S. Supreme Court of Miller v. Alabama. Upon review of the Miller decision, which banned mandatory life without parole sentences for juveniles, the Court found that supplemental briefing was warranted to resolve the issues upon which it granted allowance of appeal. Accordingly, Juvenile Law Center and the other parties were ordered to submit supplemental briefing on the following issues:

  1. What is, as a general matter, the appropriate remedy on direct appeal in Pennsylvania for a defendant who was sentenced to a mandatory term of life imprisonment without the possibility of parole for a murder committed when the defendant was under the age of eighteen?
  2. To what relief, if any, is appellant entitled from the mandatory term of life imprisonment without parole for the murder he committed when he was fourteen years old? 

The brief argued that, based on Miller, Pennsylvania's statutory scheme of sentencing any juvenile convicted of first or second degree murder to life without parole is now unconstitutional, and that Batts' sentence must be vacated and a new constitutional sentence imposed. The brief argued that the only constitutional statutory sentence available is the sentence for lesser included offenses, and that the Court should hold that the appropriate remedy for juveniles convicted of first degree murder is to impose the current statutory sentence for the lesser included offense of third degree murder.

Deputy Director Marsha Levick argued before the Pennsylvania Supreme Court on behalf of Batts on September 12, 2012. View a video of her argument here (scroll to 31:00). 

On March 26, 2013, the Pennsylvania Supreme Court held that Batts was entitled to a resentencing hearing. At that resentencing, Batts can receive a sentence of life with parole or life without parole. The Court gave the trial court the discretion to determine Batts' minimum sentence (or parole eligibility), emphasizing that trial courts must consider "appropriate-age related factors." The Court relied in part on the United States Supreme Court's decision in Miller


Further Reading

"Easton teen killer's fate to be decided by Northampton County Judge Koury," Riley Yates, Allentown Morning Call, 4/2/13

Blog post: Juvenile Law Center Responds to Pennsylvania Supreme Court's Ruling in Commonwealth v. Batts, 3/26/13

"Supreme Court: Juvenile killer to get new sentencing," Riley Yates, Allentown Morning Call, 3/26/13

"14-year-old convicted of Easton murder should only face 40 years in prison, attorneys argue," Tom Shortell, The Express-Times, 7/27/12

"Easton teen's life sentence for gang killing to be argued," JD Malone, Allentown Morning Call, 7/10/12

"Northampton County prosecutors seeking life sentence for Qu'eed Batts, despite high court ruling," Andrew George, The Express-Times, 7/10/12

Details

Citation
Not Reported
Case Number
79 MAP 2009
Type
Amicus Curiae
Date
August 26, 2010
Court
Pennsylvania Supreme Court
State of Origin
Pennsylvania