Chandler v. Mississippi

In 2005, Joey Chandler was convicted for the murder of his cousin Emmitt Chandler and sentenced to life in prison under Mississippi Code Section 97-3-21 (2005). His conviction and sentence was affirmed on appeal. In 2015, Chandler received a new sentencing hearing for his murder conviction in light of the United States Supreme Court’s decision in Miller v. Alabama, 567 U.S. 460 (2012). Following the hearing, the circuit court sentenced Chandler to life in prison. Chandler appealed, requesting that he be resentenced because the trial court failed to analyze all the factors identified in Miller and adopted in the Mississippi Supreme Court’s subsequent decision in Parker v. Mississippi, 119 So. 3d 987 (Miss. 2013). The Mississippi Supreme Court affirmed, finding the trial court did not automatically resentence Chandler to life in prison or perceive a legislative mandate that Chandler must be sentenced to life in prison without parole in violation of Miller. As required by Miller and the subsequent decision in Parker, the trial court held a hearing and, after considering all that was presented as well as the entire court file, sentenced Chandler to life in prison. The trial court took into account the characteristics and circumstances unique to juveniles. Although the trial court had the authority to sentence Chandler to life in prison with the possibility of parole, it chose to sentence Chandler to life in prison, which was also within its authority. Because the trial court satisfied its obligation under Miller and Parker, the Supreme Court found the trial court did not abuse its discretion in sentencing Chandler to life in prison. View "Chandler v. Mississippi" on Justia Law