June 28, 2017

Colorado Supreme Court: Graham and Miller Do Not Apply to Aggregate Term-of-Years Sentences

The Colorado Supreme Court issued its opinion in Armstrong v. People on Tuesday, May 30, 2017.

Life without parole—Juveniles—Eighth Amendment.

The supreme court considered whether Graham v. Florida, 560 U.S. 48 (2010), and Miller v. Alabama, 132 S. Ct. 2455 (2012), apply to aggregate term-of-years sentences imposed on juvenile defendants convicted of multiple offenses. For reasons discussed at length in the lead companion case, Lucero v. People, 2017 CO 49, __ P.3d __, announced the same day, the court held that Graham and Miller do not apply to aggregate term-of-years sentences imposed for multiple offenses. The court therefore held that Graham and Miller do not apply to Armstrong’s aggregate term-of-years sentence. Accordingly, the court of appeals’ judgment was affirmed.

Summary provided courtesy of The Colorado Lawyer.

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