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Saddler v. Pash

United States District Court, E.D. Missouri, Eastern Division

February 21, 2018

RONDA PASH, et al., Respondent.



         This matter is before the Court on the petition of Missouri state prisoner Carlos Saddler, who is represented by counsel, for a writ of habeas corpus pursuant to 28 U.S.C. § 2254. For the reasons set forth below, federal habeas relief will be denied.


         The record establishes that, on February 27, 1998, Petitioner was sentenced in Missouri state court to a mandatory term of life without parole after being convicted of crimes he committed when he was under 18 years old.[1] On June 25, 2012, the United States Supreme Court issued its opinion in Miller v. Alabama, 567 U.S. 460 (2012), in which it held that the Eighth Amendment prohibits mandatory sentences of life without parole for juvenile offenders. The Court reasoned that “[m]andatory life without parole for a juvenile precludes consideration of his chronological age and its hallmark features-among them, immaturity, impetuosity, and failure to appreciate risks and consequences, ” the “family and home environment that surrounds him-and from which he cannot usually extricate himself-no matter how brutal or dysfunctional, ” the “circumstances of the homicide offense, ” and “the possibility of rehabilitation . . . .” Id. at 477-78.

         On January 27, 2016, in the case Montgomery v. Louisiana, 136 S.Ct. 718 (2016), the Supreme Court held that Miller announced a new substantive constitutional rule that applied retroactively to cases on collateral review. 136 S.Ct. at 736. But the Court clarified that this retroactive application “does not require States to relitigate sentences, let alone convictions, in every case where a juvenile offender received mandatory life without parole. A State may remedy a Miller violation by permitting juvenile homicide offenders to be considered for parole, rather than by resentencing them.” Id. As to this remedy, the Court cited a Wyoming statute that allows a juvenile convicted of homicide to be eligible for parole after 25 years of incarceration. Id. (citing Wyo. Stat. Ann. § 6-10-301(c) (2013)). The Court specifically held that “[a]llowing those offenders to be considered for parole ensures that juveniles whose crimes reflected only transient immaturity-and who have since matured-will not be forced to serve a disproportionate sentence in violation of the Eighth Amendment.” Id.

         Based on Miller and Montgomery, Petitioner filed a petition for a writ of habeas corpus in state court on June 22, 2013. On March 15, 2016, the Missouri Supreme Court issued an order that applied to Petitioner's case and other similarly situated cases. The order stated that the Missouri General Assembly had yet to enact a constitutionally valid sentencing provision in accordance with Miller and Montgomery. Therefore, the Missouri Supreme Court held that Petitioner and those similarly situated shall be eligible to apply for parole after 25 years' imprisonment on their sentences of life without parole unless their sentences were otherwise brought into conformity with Miller and Montgomery by the action of the governor or enactment of necessary legislation. Following this ruling, Petitioner filed a motion for reconsideration or for resentencing in the Missouri Supreme Court.

         On March 17, 2016, Petitioner filed this federal habeas petition, arguing that the Missouri Supreme Court's March 15, 2016 order violated his constitutional rights because it constituted an illegal alteration of the unlawful sentence imposed on Petitioner.

         On July 19, 2016, the Missouri Supreme Court entered an order vacating its March 15, 2016 order, overruling as moot the motions for reconsideration or resentencing filed by Petitioner and others, and denying Petitioner's and others' state court petitions for habeas corpus, all in light of in light of the enactment of Missouri Senate Bill No. 590 (“SB 590”). SB 590, signed into law on July 13, 2016, and codified at Mo. Rev. Stat. § 558.047, states, in relevant part:

1. Any person sentenced to a term of imprisonment for life without eligibility for parole before August 28, 2016, who was under eighteen years of age at the time of the commission of the offense or offenses, may submit to the parole board a petition for a review of his or her sentence regardless of whether the case is final for purposes of appeal, after serving twenty-five years of incarceration.
. . . .
4. The parole board shall hold a hearing and determine if the defendant shall be granted parole.
5. In a parole review hearing under this section, the board shall consider, in addition to the factors listed in section 565.033:
(1) Efforts made toward rehabilitation since the offense or offenses occurred, including participation in educational, vocational, or other programs ...

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