Brown v. Hobbs

Summary

The Supreme Court of Arkansas affirmed the dismissal of Jeffery Brown’s habeas corpus petition challenging his life sentence for first-degree murder under Miller v. Alabama and related Arkansas precedent. The court held that Brown’s sentence was discretionary rather than mandatory, so Miller’s restrictions on mandatory juvenile life-without-parole sentences did not apply. Brown therefore failed to show that his commitment was facially invalid or that the sentencing court lacked jurisdiction.

Holdings

1. Miller v. Alabama does not render Brown's discretionary life sentence for first-degree murder illegal because Miller prohibits sentencing schemes that mandate life without parole for juvenile homicide offenders, and Brown's applicable sentencing range included a discretionary life sentence.
2. Brown was not entitled to habeas corpus relief because he failed to show that the circuit court lacked jurisdiction or that his commitment was invalid on its face.

Questions Presented

1. Whether Brown's discretionary life sentence for first-degree murder was facially illegal under the Eighth Amendment and Miller v. Alabama because he was a juvenile and the sentencing court did not consider his youth.
2. Whether Brown established a basis for state habeas corpus relief by showing that the sentencing court lacked jurisdiction or that his commitment was invalid on its face.

Disposition

affirmed