Sentencing of a juvenile offender; Miller v Alabama; Life imprisonment without the possibility of parole (LWOP); People v Snow

The court held that the “trial court properly considered factors outlined in Miller before imposing a sentence within the statutory guidelines range and considered [defendant-Logan’s] youth as a mitigating factor at sentencing.” He was convicted of first-degree felony murder, armed robbery, conspiracy to commit armed robbery, and felony-firearm for offenses he committed when he was 16 years old. He was sentenced as an adult to a mandatory term of LWOP for his felony-murder conviction. Following Miller, the trial court resentenced him to 35 to 60 years. The volume of analysis alone contradicted Logan’s claim that the trial “court gave inadequate mitigating weight to the characteristics of youth in imposing sentence.” The court noted the trial court “acknowledged that Logan’s decisions at that point in his life were driven by his need to escape his home environment.” The trial court “clearly explained why mitigation was not available on this factor, but balanced this consideration with the other factors and circumstances identified.” The court held that the trial court identified and analyzed each Miller factor in turn. Although the trial “court did not specifically list the objectives of Snow, the court’s on-the-record analysis covered those factors as well. And the court considered the hallmarks of Logan’s youth as a mitigating factor.” The trial court’s “analysis of the Miller factors and their application under the circumstances of this case justified the court’s determination that a 40-year minimum sentence was not justified, but that a minimum sentence within the middle-to-high end of the range was. [It] discussed Logan’s rehabilitative efforts and successes at length, while acknowledging the seriousness of the offense. Overall, the sentencing court conducted the required analysis, found that Logan’s youth was a factor mitigating against the highest permissible sentence, and fashioned a proportionate sentence.” Affirmed.