Lawton v. State

In this case, the Third District Court of Appeal read Graham v. Florida as creating a homicide-case exception to the categorical rule against sentencing a juvenile offender to life without parole for a nonhomicide crime. The court’s reading would permit a juvenile to be sentenced to life without parole for a nonhomicide offense if the juvenile also committed a homicide in the same criminal episode. Applying this homicide-case exception, the Third District held that Defendant’s life-without-parole sentences for certain nonhomicide offenses committed as a juvenile were constitutional under Graham because Defendant also committed a homicide in the same criminal episode. The Supreme Court quashed the Third District’s decision, holding that Graham’s categorical rule leaves no room for the homicide-case exception recognized by the state’s Second, Third, and Fourth District Courts of Appeal. Remanded with instructions that Lawton be resentenced for the nonhomicide offenses of attempted first-degree murder with a firearm and armed robbery with a firearm. View "Lawton v. State" on Justia Law