State v. McDougald
William McDougald, a Black man, was sentenced to mandatory life without parole (LWOP) under North Carolina’s Violent Habitual Felon (VHF) statute. Mr. McDougald’s VHF status was based, in part, on an offense that occurred when he was sixteen.
Juvenile Law Center, joined by ACLU of North Carolina, Council for Children’s Rights, Emancipate NC, and North Carolina Justice Center, filed an amicus brief in the North Carolina Court of Appeals in support of Mr. McDougald. Our brief argued that Mr. McDougald’s sentence flouts constitutional limitations on juvenile sentencing, including U.S. Supreme Court precedent prohibiting the imposition of mandatory LWOP based on juvenile conduct. We further argued that Mr. McDougald’s sentence contravenes North Carolina’s current legislative understanding of youth and extends the state’s racially disparate treatment of Black youth. Specifically, we emphasized that North Carolina’s criminal laws, including the habitual felon statute, are applied in a racially discriminatory manner, which exacerbates disparities in lengthy sentences.
The North Carolina Court of Appeals held that the application of the VHF statute to Mr. McDougald, and his resulting LWOP sentence, is constitutional. The Court further held that Mr. McDougald’s sentence is not disproportionate under the Eighth Amendment and additionally rejected his claim of ineffective assistance of counsel.
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