State of New Hampshire v. Eduardo Lopez, Jr.

Summary

The New Hampshire Supreme Court affirmed a 45-years-to-life sentence imposed on Eduardo Lopez, Jr., who committed first-degree murder at age 17. The court held that the sentence, which allows parole consideration at age 62, is not the de facto equivalent of life without parole under the Eighth Amendment. The court also upheld the trial court’s reliance on CDC life-expectancy tables and declined to adopt a bright-line rule treating sentences longer than 35 years as de facto life sentences.

Holdings

1. A 45-year-to-life sentence that permits the defendant to be considered for parole at age 62 is not, on the record presented, the de facto equivalent of life without parole under the Eighth Amendment.
2. The trial court did not abuse its discretion or act unreasonably by finding the CDC life-expectancy tables more reliable than the defendant's prisoner-based ACLU study, assuming life-expectancy evidence was relevant.
3. The court declined to create a bright-line constitutional rule that a term-of-years sentence exceeding 35 years is the de facto equivalent of life without parole.

Questions Presented

1. Whether a 45-year-to-life sentence imposed on a juvenile homicide offender is the de facto equivalent of life imprisonment without parole under the Eighth Amendment.
2. Whether the trial court improperly relied on general-population CDC life-expectancy tables rather than prisoner-specific life-expectancy studies.
3. Whether the Eighth Amendment requires a bright-line rule that any term-of-years sentence exceeding 35 years is the de facto equivalent of life without parole.
4. Whether the sentence required a Miller-type finding that the defendant was among the rare juvenile offenders whose crimes reflected irreparable corruption or permanent incorrigibility.

Disposition

affirmed