Florida Judge Says Mandatory Minimums for Minors Unconstitutional
A Florida judge has recently ruled that mandatory minimums for minors are unconstitutional. Judge William Fuente, a judge on the 13th Judicial Circuit Court, handed down an opinion that held that mandatory minimums for minors violates the eighth amendment prohibition on cruel and unusual punishment. In order to fully understand the ruling, it is important to understand mandatory minimums themselves, as well as precedent related to eighth amendment jurisprudence and how juveniles are sentenced.
Mandatory minimums are sentences that do not allow the judge any discretion in sentencing and instead mandate that they impose a sentence of at least a specific amount of jail or prison time. Florida has many crimes that come with mandatory minimum sentences. In these cases, even if there are extenuating circumstances, if the defendant is found guilty, judges are still not able to sentence them to less time than the mandatory minimum requires.
This case centers around a Florida law that sets a 40-year mandatory minimum prison sentence for any minor who attempted to kill, intended to kill, or killed someone.
The eighth amendment to the United States Constitution prohibits cruel and unusual punishment. What qualifies as cruel and unusual punishment is decided by the courts and changes over time and with context. For example, what is cruel and unusual for a juvenile who commits a crime may not be cruel and unusual for an adult in the same situation. The court has required that the law not view children “simply as miniature adults” when it comes to sentencing and punishment.
Judge Fuente relied heavily on precedent in this case and especially the 2012 Supreme Court decision in Miller v. Alabama. Miller was quite similar to the case at hand and the Supreme Court found that Alabama unconstitutionally violated the eighth amendment. In that case Alabama’s mandatory life without parole sentences for juveniles convicted of specific crimes was stricken down.
The justices in Miller found it troubling that the court was not able to take into account specific circumstances of the juvenile’s life, such as extreme abuse, immaturity, mental ability, and other related factors. The court in Miller found that it is important to look at all the relevant factors during the sentencing process for juveniles and also the circumstances of the crime and the extent of the juvenile’s involvement in the crime.
Based on the holding in Miller, Judge Fuente struck down Florida’s 40-year mandatory minimum sentence for juveniles. Judge Fuente believes that constitution requires courts to look at the individual circumstances of the juvenile and to sentence him or her based on the possible mitigating factors rather than a “one size fits all” punishment scheme.
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