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Keywords

appealhearingpleaparoleno contest plea

appealhearingparole

Related Cases

Fletcher v. State, 532 P.3d 286

Facts

Winona M. Fletcher, at the age of 14, committed three murders during an armed robbery with her boyfriend. After a waiver hearing, she was tried as an adult and entered a no contest plea to two counts of first-degree murder and one count of second-degree murder. She was sentenced to three consecutive 45-year terms, totaling 135 years. Fletcher's upbringing was marked by trauma and instability, and her boyfriend testified against her, claiming she was not coerced into the crimes.

In 1985, when Fletcher was fourteen years old, she and her nineteen-year-old boyfriend, Cordell Boyd, forced their way into an occupied residence at gunpoint in order to commit an armed robbery. While inside, they killed all three occupants of the home: sixty-nine-year-old Tom Faccio, seventy-year-old Ann Faccio, and Ann Faccio's sister, seventy-five-year-old Emilia Elliot. Fletcher shot Ann Faccio and Emilia Elliot, and Boyd shot Tom Faccio.

Issue

Did Fletcher's sentence constitute cruel and unusual punishment under the Eighth Amendment, and was she entitled to resentencing considering her youth and its characteristics?

Rule

The court applied the principles established in Miller v. Alabama, which require that a juvenile's youth and its attendant characteristics be considered before imposing a sentence that is the functional equivalent of life without parole.

Analysis

The court found that Fletcher's sentence of 135 years was effectively a life sentence without the possibility of parole, which required a consideration of her youth and its characteristics during sentencing. The court noted that Fletcher did not receive a sentencing hearing that adequately addressed these factors, as mandated by Miller, and thus her sentence was unconstitutional.

Conclusion

The court affirmed in part, reversed in part, and remanded the case for resentencing, determining that Fletcher's sentence was unconstitutional under the Eighth Amendment due to the lack of consideration of her youth.

Who won?

Winona M. Fletcher prevailed in her appeal as the court found her sentence unconstitutional and warranted a remand for resentencing.

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Keywords

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