Summary
The Minnesota Supreme Court held that the rule announced in Miller v. Alabama does not apply retroactively to a juvenile offender whose mandatory life-without-release sentence became final before Miller was decided. The court concluded that the postconviction petition was time-barred, rejected a mootness challenge and a request to overrule Chambers v. State, and declined to grant relief under its supervisory powers. The court reversed the postconviction court's order and reinstated Roman Nose's original sentence.
Topics
Practice areas
Questions Presented
- Whether the State's appeal was moot because reinstating Roman Nose's original life-without-release sentence would allegedly impose an unconstitutional sentence.
- Whether Miller v. Alabama applies retroactively to a juvenile whose mandatory life-without-release sentence became final before Miller was announced.
- Whether Roman Nose was entitled to relief under the Minnesota Supreme Court's supervisory powers to ensure the fair administration of justice even if Miller was not retroactive.
Holdings
- The State's appeal was not moot because the court could grant effectual relief by reversing the postconviction order and reinstating the original sentence.
- The Miller rule does not apply retroactively to a juvenile whose life-without-the-possibility-of-release sentence became final before Miller was announced.
- Roman Nose was not entitled to relief under the court's supervisory powers because the case did not present exceptional circumstances warranting a sentence reduction.
Key quotations
“a judge or jury must have the opportunity to consider mitigating circumstances before imposing the harshest possible penalty for juveniles.” (196)
“Because we are able to grant effective relief, we hold that the State’s appeal is not moot.” (198)
“The Miller rule does not apply retroactively to a juvenile whose sentence of LWOR became final before the Miller rule was announced.” (201)
“We have never used our supervisory powers to effectively overrule precedent for only one defendant while maintaining case law on the books that binds others who are similarly situated, and we decline to do so now.” (202)
Factual background
Roman Nose was 17 years and 10 months old when he committed the murder of Jolene Studemann in July 2000. A Washington County jury convicted him of first-degree murder while committing or attempting to commit first- or second-degree criminal sexual conduct and first-degree premeditated murder. The district court imposed life without the possibility of release under Minnesota's mandatory juvenile sentencing scheme.
Procedural history
A Washington County jury convicted Roman Nose of first-degree murder offenses arising from the 2000 murder of Jolene Studemann, and the district court imposed the mandatory sentence of life without the possibility of release. The Minnesota Supreme Court affirmed his conviction on direct appeal in 2003. After Miller was decided in 2012, Roman Nose sought postconviction relief; the postconviction court held that Miller applied retroactively and resentenced him. The State appealed, and the Minnesota Supreme Court stayed the appeal pending its decision in Chambers v. State.
Remand instructions
The postconviction court's January 28, 2012 order was reversed, and Roman Nose's original sentence of life without the possibility of release was reinstated.