Juvenile Law Center Responds to Pennsylvania Supreme Court's Ruling in Commonwealth v. Batts

Juvenile Law Center,

On March 26, 2013, the Pennsylvania Supreme Court in Commonwealth v. Batts held that Qu’eed Batts, who received a mandatory life without parole sentence for a crime he committed when he was 14, was entitled to a resentencing hearing. At that resentencing, Mr. Batts can receive a sentence of life, leaving the trial court the discretion to set the minimum term that Mr. Batts must serve. 

In setting the mininum term (or parole eligibility), the Pennsylvania Supreme Court emphasized that trial courts must consider “appropriate age-related factors,” such as the “juvenile’s age at the time of the offense, his diminished culpability and capacity for change, the circumstances of the crime, the extent of his participation in the crime, his family, home and neighborhood environment, his emotional maturity and development, the extent that familial and/or peer pressure may have affected him, his past exposure to violence, his drug and alcohol history, his ability to deal with the police, his capacity to assist his attorney, his mental health history, and his potential for rehabilitation.” The Pennsylvania Supreme Court relied in part on the United States Supreme Court’s decision in Miller v. Alabama, which held that mandatory life sentences, without the possibility of parole, were unconstitutional when applied to juveniles. 

"The decision in Batts is consistent with the U.S. Supreme Court’s emphasis in Miller that children who commit crimes – even violent crimes – are entitled to individualized sentences that take into account their diminished culpability," says Robert Schwartz, Executive Director of Juvenile Law Center. "While the Pennsylvania Supreme Court did not prohibit juvenile life without parole sentences, the Court noted the U.S. Supreme Court’s finding that “the occasion for such a punishment would be ‘uncommon.'" According to Mr. Schwartz, "Under Miller and Batts, trial courts must take into account how children are different from adults, and they must consider how these differences caution against sentencing any child to a lifetime in prison."

The decision in Commonwealth v. Batts applies to juveniles whose homicide convictions were still on appeal at the time the United States Supreme Court decided Miller v. Alabama. The Pennsylvania Supreme Court has yet to decide Commonwealth v. Cunningham, a companion case to Batts, in which it will rule on whether Miller should apply retroactively in Pennsylvania. Juvenile Law Center has taken the position that Miller should be retroactive, and should apply to the roughly 500 juveniles serving mandatory life sentences in the Commonwealth. 

The next step for juveniles in Batts’s position is a resentencing hearing before the trial judge.

Further Reading

Juvenile Life Without Parole in Pennsylvania

"Supreme Court: Juvenile killer to get new sentencing," Riley Yates, Allentown Morning Call, 3/26/13

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