U.S. District Court Dismisses Petition Arguing that California Statutes’ Inconsistencies Violate the Eighth Amendment

Above: Mule Creek State Prison, where Coleman is currently incarcerated. (LA Times)

On December 21, 2020, a magistrate judge in the United States District Court for the Eastern District of California recommended that the petition of Raymond Nelson Coleman be dismissed. Coleman had petitioned for recall and resentencing because he was sentenced to LWOP for crimes he committed at age 21. His petition challenged the age discrepancy in two California statutes concerning LWOP sentences for juveniles and young adults.

In 2006, Coleman was convicted of first-degree murder and robbery, offenses he committed at age 21. He was sentenced to LWOP. In 2016, he filed a petition for recall of his sentence, which was dismissed. This dismissal was upheld by the California Supreme Court.

Coleman then filed a federal petition, challenging “the refusal of the California courts to recall his sentence of life imprisonment without the possibility of parole (LWOP) based on his age when the underlying offenses were committed.”

Recent California legislation has addressed the issue of LWOP sentences for juveniles and young adults. Section 3051 of the California Penal Code was extended to mandate parole hearings for those age 25 and below at the time of their offenses, except those sentenced to LWOP. Section 1170 allows those who were sentenced to LWOP and were 18 or younger at the time of their offenses to petition for recall and resentencing after 15 years of incarceration. This framework excludes the group of offenders who were sentenced to LWOP for crimes committed between the ages of 18 and 25 from these protections.

In his petition, Coleman argued that “the scientific and social policy reasons” for the expansion of Section 3051 should apply to Section 1170 as well, “alleg[ing] in essence that the discrepancy between the age thresholds in Sections 1170 and 3051 violates equal protection[.]” He claimed that “[t]he neuroscience of brain development shows that young adults, not just juveniles, lack the cognitive capabilities of a more mature adult and thus show greater potential for rehabilitation as they mature. All youth offenders are similarly situated by virtue of their still developing brains, regardless of the crimes they commit or the statutes under which they are punished.”

The magistrate judge recommended that the U.S. District Court find that “there is nothing irrational about having different age-based standards for the recall of LWOP sentences” and that the “legislative distinction between LWOP and parole-eligible offenders is no more constitutionally suspect that the distinction between 18 year old and 25 year old offenders.” The magistrate judge found that this distinction is consistent with Miller and “is rationally related to the state’s legitimate goal of identifying prisoners who may be most receptive to rehabilitative efforts.” Thus, the magistrate judge recommended that the District Court dismiss Coleman’s petition.

Citation: Coleman v. Covello, 2020 WL 7490082

Keywords: LWOP, Miller v. Alabama, adolescent brain, young adult, California

This post is the 80th 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.




at Mass General Hospital, Harvard Medical School

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at Mass General Hospital, Harvard Medical School

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