State v. Williams-Bey
Tauren Williams-Bey was sentenced to 35 years for his participation as an accessory to a homicide committed when he was 16. The court did not consider his youth and youth-related factors required by Miller when imposing his sentence and rather than providing Mr. Williams-Bey and others similarly situated with a resentencing hearing, Connecticut instead relies on future parole hearings.
Juvenile Law Center filed an amicus brief in the Connecticut Supreme Court in support of Mr. Williams-Bey. Our brief argued that parole availability does not remedy a sentencing court's failure to give mitigating effect to the youth-related factors set forth in Miller.
Nevertheless, the Connecticut Supreme Court held that "parole eligibility afforded by [state statute] is an adequate remedy for a Miller violation under the Connecticut constitution." However, Justice Ecker's dissent stated: "I am of the view that mandatory minimum sentences designed for adult offenders cannot constitutionally be applied to juvenile offenders tried as adults without providing an individualized sentencing proceeding in which the sentencing judge must consider the mitigating effects of youth and its associated features."
Mr. Williams-Bey was granted parole while awaiting the Connecticut Supreme Court's decision.