In the United States criminal justice system we differentiate between crimes that only require an act and crimes that require intent. Colloquially, we often refer to crimes requiring only intent as “statutory” crimes; by way of example, no mindset is required to prove that someone is guilty of sexual acts with a minor. Intent, or proof that someone committed a criminal act on purpose, comes into play during both the trial phase and the sentencing phase. Where a guilty person acted without intent, for example, they may receive a lighter sentence than someone acting purposefully.
Questions of intent are often complicated where someone does not have an ability to form an intent, or at least the same ability as the average, fully developed adult. Where a person is under the influence of drugs, acting under a threat against their own life, or mentally handicapped, courts have found that the question of intent is complex. This is also true where the criminal is a child. Recently, a Pennsylvania panel of appellate court judges found that a life sentence for murder was acceptable, even where the murderer was a child.
On February 7, 2006 Qu’eed Batts was a 14-year-old child in Easton, Pennsylvania. He was beginning high school along with his peers. He was too young to buy cigarettes, vote, or even drive a car with a learner’s permit. He was not too young, however, to find himself involved in gang life. On February 7th Batts shot and killed a young man named Clarence Edwards. Batts has maintained since that time that he was ordered to kill Edwards by a gang member. Batts was initiated into the gang on his own front porch as a 12-year-old. During trial Batts was convicted of murder and sentenced to spend the remainder of his life in prison. This left human rights advocates asking one important question: in a criminal justice system that punishes such crimes based on intent, how can a 14-year-old be found developmentally capable of forming this intent?
Fast forward to 2014 and the United States Supreme Court (SCOTUS) is asked this same question. In Miller v. Alabama the Court ruled that a mandatory sentence of life without the possibility of parole was unconstitutional for juvenile offenders. The Court did not ban life sentences for inmates in Batts’ situation; it merely ruled that the sentence could not be required by law. The Court reasoned that juveniles, being developmentally immature, should not be held to the same standard as adults. Batts appealed his sentence based on this SCOTUS ruling. Earlier this month Batts’ hope of spending any of his adulthood outside of prison walls was once again shot down. A panel of Pennsylvania appellate court judges ruled 2-1 that Batts’ sentencing would not be overturned. The judges determined that the sentencing judge was within his lawful discretion to sentence Batts to life without parole and that Batts’ right to due process was not denied.
When it comes to filing a criminal appeal, everything is on the line. Having a skilled and knowledgeable criminal appeals attorney is your best chance at success. If you have questions about how to file a criminal appeal, contact our team at Brownstone Appellate Law Firm today.Tags: Clarence Edwards., miller v alabama, Qu’eed Batts, United States Supreme Court
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