Indiana Supreme Court Reduces 138 Year Sentence, Citing Adolescent Brain Science

Above: Defendant Matthew Stidham — Image Source: Star Press

On November 17, 2020, the Supreme Court of Indiana reduced Matthew Stidham’s sentence from 138 years to 88 years for crimes he committed at the age of seventeen, deeming the maximum term-of-years sentence imposed as inappropriate. The decision referenced adolescent brain science in its analysis.

In 1991, Matthew Stidham and two others were convicted of murdering Daniel Barker and related crimes from the incident, including robbery, criminal confinement, battery, and auto theft. Stidham, 17 at the time of the murder, was sentenced to the maximum aggregate term of 141 years. In 1994, Stidham appealed his sentence on the grounds that certain evidence had been improperly admitted at trial and was ultimately resentenced to 138 years for his crimes.

Between 1994 to 2020, Stidham filed numerous further appeals in an attempt to reduce his sentence, but the courts continuously declined to revise his sentence, stating that Stidham’s sentencing issues had already been sufficiently resolved during his 1994 appeal.

In Stidham’s most recent appeal to the Supreme Court of Indiana, he argued that because he was a juvenile at the time of his crimes, his de facto life-without-parole sentence was in violation of both the 8th Amendment of the United States Constitution as well as the Indiana Constitutions.

In reviewing Stidham’s case, the court noted extraordinary circumstances in which “two major shifts in the law — one easing the standard by which we exercise our power to review and revise sentences and another limiting the applicability of the most severe sentences to children — render suspect Stidham’s maximum sentence for crimes he committed as a juvenile.”

Ultimately, the court found Stidham’s maximum sentence to be inappropriate due to his age at the time he committed his crimes and reduced his sentence from 138 years to 88 years. To support their decision, the court provided numerous citations of adolescent psychological and neuroscientific evidence from the U.S. Supreme Court decisions Miller, Brown, and Graham:

“Both the U.S. Supreme Court and this Court have recognized that, ‘[b]ecause juveniles have diminished culpability and greater prospects for reform,’ they ‘are less deserving of the most severe punishments.’ This conclusion flows from the recognition of three important differences between children and adults. First, juveniles’ ‘lack of maturity and . . . underdeveloped sense of responsibility’ leads to ‘recklessness, impulsivity, and heedless risk-taking.’ Second, their susceptibility ‘to negative influences and outside pressures,’ along with their limited ability to control their environment, can leave them lacking ‘the ability to extricate themselves from horrific, crime-producing settings.’ Third, ‘a child’s character is not as well formed as an adult’s; his traits are less fixed and his actions less likely to be evidence of irretrievable depravity.’ These salient characteristics mean that ‘[i]t is difficult even for expert psychologists to differentiate between the juvenile offender whose crime reflects unfortunate yet transient immaturity, and the rare juvenile offender whose crime reflects irreparable corruption.’”

Further, the court relied on evidence regarding Stidham’s potential for rehabilitation, noting the obtainment of his G.E.D., associate’s degree, and bachelor’s degree, completion of a prison culinary arts program, and work as a firefighter in the prison department for approximately fifteen years despite “staring down a 138-year sentence that all but guaranteed he would die behind bars.”

Finally, they stated that “while Stidham’s crimes were horrific, his character makes this case less suitable for a maximum term-of-years sentence. Stidham’s status as a juvenile, his difficult childhood, and his initial steps toward rehabilitation between his first trial and his retrial demonstrate that he was not one of the worst offenders subject to the harshest punishment.”

Key words: Miller v. Alabama, adolescent brain, juvenile offender, sentencing, Indiana

Citation: State v. Stidham, 157 N.E.3d 1185 (Ind. 2020) (Ind., 2020), reh’g denied (Jan. 12, 2021)

This post is the 27th post as part of an ongoing Center for Law, Brain & Behavior (CLBB) series tracking the latest developments in law and neuroscience cases. To see previous posts about recent cases, see the full case archive on the CLBB website. To see updates on legal scholarship, see the Neurolaw News, hosted by the MacArthur Foundation Research Network on Law and Neuroscience. This project is made possible through support of the Dana Foundation.

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