State v. Arias
Jonathan Arias was sentenced to life without parole for an offense committed as a youth. After the U.S. Supreme Court decisions in Miller v. Alabama and Montgomery v. Louisiana, the Maricopa County Attorney’s Office (MCAO) stipulated that Mr. Arias was entitled to resentencing. However, MCAO withdrew from the stipulation following the U.S Supreme Court’s decision in Jones v. Mississippi, and the sentencing court dismissed the case. Since the 2012 decision in Miller, no youth sentenced in Maricopa County under Arizona’s mandatory life without parole scheme has been resentenced.
Juvenile Law Center joined the Arizona Justice Project in filing an amicus brief in the Arizona Court of Appeals in support of Mr. Arias. The brief argued that Mr. Arias’s sentence is unconstitutional under Miller, as at the time of his sentencing Arizona law did not allow the court to impose a parole-eligible sentence. The brief further argued that the U.S. Supreme Court’s decision in Jones does not affect the unconstitutionality of Mr. Arias’s sentence under Miller or reflect a change in controlling law.
The Arizona Court of Appeals held that Jones did not modify or overrule the Arizona Supreme Court’s previous application of Miller and Montgomery, and that the State remains bound by its stipulation to resentencing.