Mandatory Minimums

Mandatory Life Sentences for Juvenile Homicide Offenders are Unconstitutional, Rules Tennessee Supreme Court

The court says a 51-year "life" sentence for a 2015 murder violated the Eighth Amendment.


Tennessee's Supreme Court ruled Friday that the state's 51-year minimum sentence for juvenile homicide offenders violates the Eighth Amendment's protection against "cruel and unusual" punishment. With the ruling, such lengthy sentences for juvenile homicide offenders are effectively ended in the United States, as Tennessee was the last remaining state to require that such offenders serve at least 50 years before being eligible for parole.

The ruling was handed down in Tennessee v. Booker. Tyshon Booker had been given a "life" sentence of at least 51 but no more than 60 years for the 2015 murder of 26-year-old G'Metrik Caldwell. Booker appealed the sentence, arguing that having to wait more than half a century for a parole hearing violated the Eighth Amendment. The court agreed: While it upheld Booker's life sentence, the court ruled that he will be granted a parole hearing much earlier than before—sometime after 25 to 36 years of prison time served, following the dictates of never-repealed sentencing guidelines in effect from 1989 to 1995.

"Tennessee's life sentence when automatically imposed on a juvenile is the harshest of any sentence in the country," wrote Judge Sharon G. Lee in her opinion. "No one, including the dissent, disputes that a juvenile offender serving a life sentence in Tennessee is incarcerated longer than juvenile offenders serving life sentences in other states. For example, had Mr. Booker committed felony murder in nearby Alabama, he would have been eligible for release in fifteen years."

The state argued that elimianting such sentences would rise to "making policy," a role served for the state's legislature. Lee disagreed. The ruling does not make new state policy, she wrote; nor does it reverse Booker's "life" sentence. It merely fulfills the court's role in vacating laws that are unconstitutional. "When the Court does its duty and rules on the constitutionality of a statute, it makes no policy of its own. The Court simply implements the policy embodied in the Constitution itself," the judge wrote.

This ruling overturns the harshest juvenile homicide sentencing minimum in the nation—and reiterates the idea that the courts should treat minors differently than adults. "Mr. Booker committed a serious offense for which he deserves serious punishment. But he was only sixteen years old when he committed the offense," wrote Lee. "The United States Supreme Court has made clear that under the Eighth Amendment, youth is a factor that must be considered in sentencing."

Juveniles found guilty of homicide in Tennessee will now receive full-fledged sentencing hearings, rather than face a steep mandatory sentence that does not allow judges to take into account mitigating factors such as the offender's age.