Sentencing for first-degree murders committed by an 18-year-old; Consideration of “the attributes of youth”; Miller v Alabama; People v Parks; People v Boykin; People v Copeland; “Brevity” of the trial court’s statement in support of its sentence; Reliance on the facts of the crimes

Holding that the trial court did enough to satisfy the requirement of Parks and Boykin to consider defendant-Robinson’s youth in resentencing him for first-degree murders committed when he was 18, the court affirmed his 35-to-60 year sentences. He “murdered three strangers after a late-night sexual encounter with them.” While he argued on appeal “that the trial court’s ‘brevity’ in proclaiming his sentence” showed that it did not consider his youth as a mitigating circumstance, the court concluded that its brief statement did not “run afoul of Parks and its progeny. Crucial here is the background animating the trial court’s discussion. [It] considered extensive materials detailing Miller’s application, expressly leading and concluding with that point, stating twice that it considered ‘the Miller factors as it relates to whether or not they would be mitigating in terms of the sentence that you would receive.’” Further, as in “Copeland, the trial court had the ‘benefit of hindsight,’ sentencing Robinson then as a 23-year-old with several years of incarceration behind him.” Thus, the court found that the record revealed “the trial court appropriately considered Robinson’s youth when resentencing him.” In addition, its heavy reliance on the facts of his “atrocious crimes does not give us pause. ‘[T]he circumstances of the crime remain a primary consideration in determining a proportionate sentence, . . . [and t]he factors of youth do not detract or preclude that consideration, they simply add’ to it.” The trial court’s statements as to “Robinson’s deliberateness reinforces its consideration of [his] youth—in its view, Robinson did not act with the typical ‘characteristics of youth’ like immaturity, impulsivity, and lack of discipline and self-restraint.” Instead, he “had time to reflect following the group sexual encounter by leaving, returning to his house, changing clothes, and then retrieving a gun, donning a mask, and returning to murder those involved. The trial court reasonably concluded that Robinson’s actions were not youthfully impulsive.”