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defendantappealtrialmotionwillleaseparole
defendantstatuteappealtrialmotionwillleaseparolelife imprisonment

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Long v. United States, 312 A.3d 1247

Facts

In the early morning hours of March 19, 1996, Colie L. Long shot and killed fourteen-year-old Ronald Williamson. After a lengthy legal process, Long was sentenced to life in prison. In November 2021, he filed a motion to reduce his sentence under the IRAA, which allows for sentence reductions for offenses committed before the defendant's 25th birthday if certain conditions are met. Long was released on parole shortly after filing his motion, but the trial court denied his request, leading to this appeal.

In 1996, Mr. Long, then eighteen years old, shot and killed fourteen-year-old Ronald Williamson. A jury convicted Mr. Long of first-degree premeditated murder while armed, among other crimes. Mr. Long was initially sentenced to life imprisonment without the possibility of parole. This court, however, twice vacated Mr. Long's sentence, and he was ultimately sentenced to life with the possibility of parole. Mr. Long became parole-eligible on October 12, 2021.

Issue

Whether a parolee is ineligible for relief under the IRAA due to their release from prison.

This appeal requires us to decide, among other issues, whether parolees are ineligible for relief under the IRAA due to their release from prison.

Rule

The IRAA allows for sentence reductions for defendants who have served at least 15 years in prison for offenses committed before their 25th birthday, provided the court finds that the defendant is not a danger to the community and that the interests of justice warrant a modification.

The IRAA provides that the Superior Court 'shall reduce a term of imprisonment imposed upon a defendant for an offense committed before the defendant's 25th birthday if' the defendant 'has served at least 15 years in prison' and the court finds, after considering the factors set forth in subsection (c) of the statute, that 'the defendant is not a danger to the safety of any person or the community and that the interests of justice warrant a sentence modification.'

Analysis

The Court of Appeals determined that the trial court erred in its interpretation of the IRAA, specifically regarding the eligibility of parolees for sentence reduction. The court clarified that a parolee's release does not automatically disqualify them from seeking relief under the IRAA, and emphasized the need for the trial court to make explicit findings regarding the defendant's danger to the community and the interests of justice.

We conclude that a parolee's release from prison does not automatically render them ineligible for a sentence reduction under the IRAA. We further conclude that the trial court committed legal error in denying Mr. Long's IRAA motion.

Conclusion

The Court of Appeals vacated the trial court's order denying Long's IRAA motion and remanded the case for reconsideration, emphasizing the need for proper legal analysis regarding the defendant's eligibility for relief.

We therefore vacate the order and remand to the trial court for reconsideration in light of this opinion.

Who won?

Colie L. Long prevailed in the appeal because the Court of Appeals found that the trial court had committed legal errors in denying his IRAA motion.

The Court of Appeals, Shanker, J., held that: 1 defendant's release on parole did not render his appeal moot; 2 as a matter of first impression, if the movant for a sentence reduction under IRAA has served requisite 15 years in prison, subsequent release on parole does not necessarily render the movant ineligible for IRAA relief; 3 as a matter of first impression, the IRAA does not render otherwise eligible parolees ineligible for relief simply by virtue of their conditional release.

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