People v. Bonilla

Juvenile Law Center filed amicus briefs on behalf of Jose Armando Alatriste, who was sentenced to 77 years to life and Joseph Bonilla, who was sentenced to 50 years to life, both for crimes they committed as juveniles.

Our briefs argued that because their sentences deprive them of a “meaningful opportunity to obtain release,” as required by the U.S. Supreme Court’s rulings in Graham v. Florida and Miller v. Alabama, their sentences are the functional equivalent of life without parole, which was held unconstitutional by Miller. Additionally, the sentencers did not consider either of their ages or the age-related factors required by Miller. Therefore, the imposition of functional life without parole in both cases was unconstitutional.

Our briefs also argued that Miller’s prohibition on mandatory life without parole applies retroactively to both Mr. Alatriste and Mr. Bonilla. Miller announced a substantive rule, which, pursuant to U.S. Supreme Court precedent, applies retroactively. Further, even assuming the rule is procedural, Miller is a watershed rule of criminal procedure that applies retroactively. Moreover, Miller must be applied retroactively because, once the Court determines that a punishment is cruel and unusual when imposed on a child, any continuing imposition of that sentence is itself a violation of the Eighth Amendment; the arbitrary date of sentencing cannot convert an otherwise unconstitutional sentence into a constitutional one.

For each case, the California Supreme Court vacated the Court of Appeals’ denial of the petition for writ of habeas corpus and ordered that the Court of Appeals issue a ruling on the issues presented by the petition.