Castaner v. State

Eavan Castaner tragically killed his ex-girlfriend when he was only 15 years old. After pleading guilty to second-degree murder, he was sentenced to 42-to-75 years in prison. Mr. Castaner subsequently appealed the sentence to the Wyoming Supreme Court.

Juvenile Law Center filed an amicus brief in support of Mr. Castaner in the Wyoming Supreme Court arguing that Mr. Castaner’s lengthy term of years sentence violates the Eighth Amendment’s prohibition on cruel and unusual punishment. First, as the U.S. Supreme Court has consistently held, children like Mr. Castaner must be treated differently than adult offenders because the unique characteristics of youth, such as transient immaturity, make them less culpable and therefore less deserving of extreme punishments. Second, Mr. Castaner’s 42-year minimum sentence not only exceeds other Wyoming sentences but also exceeds the maximum sentence allowed for second-degree murder in most jurisdictions across the country. Finally, Mr. Castaner’s sentence exceeds the maximum term of imprisonment permitted before parole eligibility – 25 years – under Wyoming law for a life sentence for first-degree murder, making his 42-year minimum sentence for second-degree murder disproportionate and arbitrary in violation of the Eighth Amendment. Accordingly, we urged the Wyoming Supreme Court to reverse the District Court judgment and sentence. 

The Wyoming Supreme Court held that a 42-to-75-year sentence for second-degree murder committed as a juvenile was not unusual under Article 1, Section 14 of the Wyoming Constitution.
 

LEGAL TEAM

Attorneys

Andrew Keats, Marsha Levick, Hannah Stommel