People v. Christensen

Summary

The California Court of Appeal affirmed a judgment imposing life without parole on 18-year-old Jeff Andrew Christensen for aggravated kidnapping involving bodily harm or confinement creating a substantial likelihood of death. The court rejected his federal and state constitutional challenges to the sentence, concluding that the sentence was not cruel or unusual or grossly disproportionate to his conduct and criminal history. The court modified the judgment by striking a $300 parole revocation fine because Christensen was ineligible for parole.

Holdings

1. The Eighth Amendment does not prohibit sentencing an 18-year-old offender to life without parole. The constitutional rules governing juvenile offenders do not extend categorically to offenders who were at least 18 when they committed the offense.
2. The life-without-parole sentence for Christensen's aggravated kidnapping is not cruel or unusual under article I, section 17 of the California Constitution because it is not grossly disproportionate to his individual culpability.
3. A parole revocation fine under Penal Code section 1202.45 may not be imposed when the defendant is ineligible for parole. The $300 fine was improperly imposed and must be stricken.

Questions Presented

1. Whether imposing life without parole on an offender who was 18 years old when he committed aggravated kidnapping violates the Eighth Amendment.
2. Whether Christensen's life-without-parole sentence is grossly disproportionate to his culpability and therefore violates article I, section 17 of the California Constitution.
3. Whether the trial court erred by imposing a $300 parole revocation fine under Penal Code section 1202.45 when Christensen was sentenced to life without parole and was ineligible for parole.

Disposition

affirmed