Commonwealth v. Stahley
Tristan Stahley was sentenced to life without parole under Pennsylvania's Miller fix statute for a murder committed when he was 16. Following the U.S. Supreme Court decision in Montgomery v. Alabama and the Pennsylvania Supreme Court decision in Batts II, Juvenile Law Center and the Office of the Montgomery County Public Defender filed an appeal to the Superior Court of Pennsylvania on behalf of Mr. Stahley. We argued that individuals sentenced under Pennsylvania's Miller fix statute prior to the decision in Batts II are entitled to a resentencing because they did not receive the Batts II protections of a presumption against juvenile life without parole and the requirement that the Commonwealth prove beyond a reasonable doubt that the juvenile was incapable of rehabilitation.
After a divided Superior Court denied Mr. Stahley relief, Juvenile Law Center and the Defenders filed a Petition for Allowance of Appeal in the Pennsylvania Supreme Court. Mr. Stahley’s case is the first appeal in Pennsylvania which raises the question of whether the Pennsylvania Supreme Court's decision in Batts II, providing for heightened protections for juveniles facing extreme sentencing, is retroactive. Our Petition urged the court to grant review in order to ensure that Batts II is given full effect and to determine if the right to effective assistance of counsel is denied where a viable claim of voluntary intoxication is not presented despite the presence of lay and expert witnesses available to support such a defense and where such a defense was not explained to a minor defendant.
The Pennsylvania Supreme Court granted Mr. Stahley’s Petition for Allowance of Appeal. Juvenile Law Center and the Defenders filed a brief arguing that Mr. Stahley’s sentence of life without parole is unconstitutional, because it was imposed without the protections of Batts II and because the court failed to consider evidence of his rehabilitation and rehabilitative potential, as well as the hallmark characteristics of youth as required by Miller.
The Pennsylvania Supreme Court held the appeal pending Jones v. Mississippi. The U.S. Supreme Court decided Jones on April 22, 2021, and the Pennsylvania Supreme Court ordered supplemental briefing on the impact of Jones on Mr. Stahley’s appeal. Our supplemental brief argued that the decision in Jones does not alter Mr. Stahley’s claim. We argued that Jones affirmed Miller and Montgomery, upon which the Pennsylvania Supreme Court based the sentencing procedures it set forth in Batts II, and that Jones explicitly permits states to set forth such sentencing procedures.
The Pennsylvania Supreme Court dismissed Mr. Stahley’s appeal as having been improvidently granted.