Juvenile resentencing; People v Boykin; Youth as mitigating factor; People v Snow; Reasonableness & proportionality; People v Steanhouse; Reassignment on remand; People v Walker

The court held that defendant’s 40-to-60-year sentence must be vacated because the trial court again failed to “treat [youth] as a mitigating factor” through the Snow framework, and it ordered resentencing before a different judge under Walker. Defendant, who was 17 when convicted of felony murder, returned for a third resentencing after prior remands. The panel reiterated that a court must “consider the defendant’s youth” and “treat it as a mitigating factor,” and that youth must be applied “in light of” the Snow considerations. Although the trial court stated that youth was “clearly a mitigating circumstance,” the panel found the analysis largely “bare references” and “factual observations,” not a substantive explanation of how youth mitigated rehabilitation, protection of society, punishment, or deterrence. For example, the trial court discussed mental-health issues and LSD use, misconduct history, and the offense details, yet still concluded that “the punishment component still inures against the defendant” without showing mitigation. Because the record again fell “short of creating a record of a substantive, individualized analysis” that could be meaningfully reviewed, the panel vacated the sentence and remanded. Applying the Walker reassignment factors, it held reassignment was warranted because the same judge had presided over three resentencings and twice failed to comply with remand instructions on youth-mitigation, making it unreasonable to expect the judge to set aside prior views without substantial difficulty. Reassignment would preserve the appearance of justice, and duplication would be limited because the record was already developed through the Miller hearing and prior proceedings.