Illinois Appellate Court Vacates 60-Year Prison Sentence Given to 16-Year-Old and Remands for New Sentencing Hearing That Complies with Miller
Recent Cases in Law and Neuroscience, Curated by the Center for Law, Brain & Behavior and the Shen Neurolaw Lab with support from the Dana Foundation
In an appeal that made significant reference to adolescent brain science, on September 25, 2020, the Appellate Court of Illinois First District vacated Roberto Haynie’s 60-year prison sentence and remanded his case to the lower court for a “new sentencing hearing that complies with Miller and Holman.”
In 2000, Haynie was convicted of first-degree murder in Chicago and was sentenced to 60 years in prison. He was 16 years old at the time of his offense. On appeal, Haynie argued that his sentence was a de facto life sentence, and thus in violation of Miller, a U.S. Supreme Court case which held that mandatory sentencing of juvenile homicide offenders (under the age of 18 at the time of his/her offense) to life sentences without parole is in violation of the Eighth Amendment of the U.S. Constitution. In a previous court case, People v. Buffer, the Illinois Supreme Court had ruled that “[i]n determining when a juvenile defendant’s prison term is long enough to be considered de facto life without parole, we choose to draw a line at 40 years.” Therefore, Haynie argued that 60-year sentence was in fact a de facto sentence. Additionally, Haynie argued that his sentence “did not give proper weight to his rehabilitative potential” a consideration that is required under Miller.
In support of his Miller claim, a clinical neuropsychologist in Haynie’s case testified that “at 16 years old, [Haynie’s] brain was immature and that, during adolescence, the brain undergoes four major developments. The period of change can result in emotion-driven behavior and affects a person’s ability to plan, make decisions, and solve problems.” The neuropsychologist also testified that Haynie’s “immature brain limited his ability to make decisions that an adult would make in the same situation.” Additionally, Haynie cited a previous decision from U.S. Supreme Court, People v. Holman, that stated “under Miller and Montgomery, a juvenile defendant may be sentenced to life imprisonment without parole, but only if the trial court determines that the defendant’s conduct showed irretrievable depravity, permanent incorrigibility, or irreparable corruption beyond the possibility of rehabilitation.” Haynie argued “the mandatory nature of his sentence did not allow the trial court to consider . . . his rehabilitative potential.”
The Illinois Appellate Court sided with Haynie on all claims that he raised, and on September 25, 2020, vacated his sentence and remanded his case for a new sentencing hearing. In its opinion, the court stated that “nothing in the record supports a finding that defendant’s conduct reflected irreparable corruption beyond the possibility of rehabilitation.”
Citation: People v. Haynie, 2020 IL App (1st) 172511
Key Words: Miller v. Alabama, de facto life sentence, LWOP, adolescent brain, Illinois
This post is 16th 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.