California Supreme Court Limits Juveniles' Prison Sentences
By Bob Egelko
A divided California Supreme Court took another step Monday to reduce lengthy prison sentences for juveniles tried as adults, ruling that terms of 50 years or more for violent sex crimes violate constitutional standards based on youths' lack of maturity and their prospect of future rehabilitation.
The court did not specify a maximum sentence for the crimes, but noted that a recent law would have made the 16-year-old defendants in the case eligible for parole hearings after 25 years if they had murdered their victims after raping them. One of the youths was sentenced to 50 years to life in prison, and the other, found to be the leader, got 58 years to life.
"A lawful sentence must offer hope of restoration ... a chance for fulfillment outside prison walls, and a chance for reconciliation with society," Justice Goodwin Liu said in the 4-3 ruling. He told a Superior Court judge to consider those factors, and the youths' backgrounds, in resentencing them.
In dissent, Chief Justice Tani Cantil-Sakauye said the sentences did not violate the constitutional ban on cruel and unusual punishment because they were within the two youths' normal life expectancies -- one would be 66 when he becomes eligible for parole, the other 74, and the average 16-year-old can now expect to live until 79. She also cited a recent state law that makes most inmates eligible for parole hearings when they turn 60 after spending at least 25 years in prison.
Both defendants will have a "realistic ... opportunity for parole within their lifetimes," and that is all the Constitution requires, Cantil-Sakauye said.
Apart from rejecting sentences that bar parole consideration for 50 years or more, the court did not specify a maximum term or tell sentencing judges exactly how it should be calculated. But a lawyer who filed arguments supporting shorter sentences said it would be enough to give them the 25-year parole eligibility that state lawmakers have provided for youths convicted of even the most serious murders.
The court is "inviting the Legislature to fix this gaping hole in the law," said attorney L. Richard Braucher of the Pacific Juvenile Defender Center. He said the ruling probably applies to fewer than 100 juveniles in California, those sentenced as adults under the state's "one-strike" law, which requires terms of at least 25 years to life for violent sex crimes.
The youths in this case, Leonel C. and William R., each was convicted of two counts of violating the one-strike law for kidnapping and raping two girls, aged 15 and 16, outside a birthday party in the San Diego County town of Rancho Peñasquitos in September 2011. They tackled both girls and forced them to walk across a street and up an embankment before the rapes, the court said. Leonel C., who held a knife to the throats of both girls, was given the 58-year sentence.
They were tried as adults under a law, approved by the voters in 2000, that allowed prosecutors to charge juveniles as young as 14 in adult court, subject to the same sentences except for the death penalty. The voters repealed that law in November 2016, now requiring approval from a juvenile court judge before such transfers, one of several actions in recent years to ease harsh punishments on juveniles.
Those include U.S. Supreme Court rulings barring death sentences and mandatory life-without-parole terms for youths under 18. California lawmakers have required parole hearings after 25 years for youths serving life terms for murder, and the state's high court has ruled previously that a sentence of 100 years or more was the unconstitutional equivalent of life without parole.
In the current case, Attorney General Xavier Becerra's office argued that the Constitution allows a youth to be sentenced to any term that provides "an opportunity for parole within his or her natural lifetime." The court disagreed.
Life expectancies vary by race and gender, Liu noted in the majority opinion, and people in prison also tend to die earlier than those outside. Youths who spend all but the last few years of their lives in prison would have little chance to "reintegrate into society" and little incentive for rehabilitation, he said.
Even youths convicted of horrendous crimes have the "capacity to change," Liu said, quoting a U.S. Supreme Court decision.
The case is People vs. Leonel C., S224564.
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