PA Supreme Court Rules Life Without Parole Sentence For Juveniles Only Appropriate Where There’s No Potential For Rehabiliation


Commonwealth v. Batts 

In Pennsylvania, juvenile offenders who have previously been sentenced to mandatory life without parole sentences have begun the process of being resentencing.  This is, in part, a result of the landmark 2010 United States Supreme Court’s decision in Graham v. Florida holding that a sentence of life without parole imposed on juveniles convicted of non-homicide offenses is unconstitutional due to scientific evidence tending to prove that juveniles can be rehabilitated.  Therefore, The Court in Graham, ruled that mandatory life sentences for juveniles served no legitimate purpose.

Then, in 2011, the Supreme Court of Pennsylvania held off on a decision in the Commonwealth v. Batts case due to a pending United States Supreme Court case, Miller v. Alabama which was to determine whether mandatory life sentences for juvenile offenders convicted of homicide offenses (as opposed to the non-homicide offenses in Graham v. Florida) were violative of the 8th Amendment prohibition on cruel and unusual punishment and, thus, unconstitutional as well.  The answer came on June 25, 2012 when SCOTUS held that mandatory life without parole sentences for juvenile offenders does violate the 8th Amendment’s prohibition on cruel and unusual punishment.  SCOTUS reasoned that kids are constitutionally different than adults for the purposes of determining punishment.  That is, kids lack a sophisticated level of maturity and sense of responsibility; children are more vulnerable to bad influences having less control over environmental factors around them; and a kid’s personality and sense of self is not as “well formed” as an adult’s is.  The Court stipulated that a sentencing court MUST consider mitigating circumstances when determining the appropriate punishment for juvenile offenders.

Less than a year later, on March 26, 2013, the Pennsylvania Supreme Court held that Qu’eed Batts needed to be resentenced.  However, as with many courtroom battles, it could not just be that easy and, unfortunately, Qu’eed Batts got his 2015 resentencing hearing in the Northampton County Court of Common Pleas only to be sentenced again to life without the possibility for parole.  Not to be defeated, he and his attorneys appealed the resentencing to the Superior Court of Pennsylvania.  The Superior Court agreed with the Common Pleas Court sentence, dealing another blow.  They appealed the Superior Court’s affirmative decision to the Pennsylvania Supreme Court and, finally, on June 26, 2017, the Supreme Court of Pennsylvania disagreed.  The Supreme Court of Pennsylvania held three things: first, that the resentence to life without the possibility of parole was illegal as disproportionate and, therefore, in contravention of the Eighth Amendment; second, that the court must provide juvenile offenders with meaningful opportunity for release based on rehabilitation and maturity; and, third, that the Commonwealth’s expert who testified at the resentencing hearing provided no support for his conclusion that the young man made sound, reasoned decisions at only 14 years old.  So, Qu’eed Batts has finally won a second, bona fide resentencing hearing for a sentence other than life.