In re the Personal Restraint of McNeil

Summary

The Washington Supreme Court considered personal restraint petitions challenging mandatory life-without-release sentences imposed on juvenile offenders convicted of aggravated first degree murder. The court held that the 2014 legislative amendments implementing Miller v. Alabama provided an adequate remedy through resentencing and did not violate the ex post facto clauses. The court denied the State’s motion to dismiss but denied the petitions because other adequate remedies were available.

Holdings

1. The Miller fix did not eliminate petitioners' ability to make the threshold showing of actual and substantial prejudice from sentences imposed in violation of Miller. The State's motion to dismiss was therefore denied.
2. The personal restraint petitions were denied because the Miller fix provided an adequate remedy through resentencing consistent with Miller.
3. The Miller fix was not an unconstitutional ex post facto law because, although retrospectively applied, it did not increase the punishment available to petitioners.
4. The court declined to consider whether a Miller-compliant sentence of life without early release is always unconstitutional under article I, section 14 because the petitions were filed more than one year after the sentences became final and no applicable exception applied.

Questions Presented

1. Whether the petitioners' personal restraint petitions should be dismissed because Washington's Miller fix provided an alternative remedy.
2. Whether the Miller fix was an unconstitutional ex post facto law because it applied to crimes committed before enactment.
3. Whether life without the possibility of early release is always unconstitutional under article I, section 14 of the Washington Constitution when imposed on a juvenile offender.

Disposition

other