Heredia, Victoriano v. Blythe, Christopher

CourtDistrict Court, W.D. Wisconsin
DecidedNovember 22, 2021
Docket3:19-cv-00338
StatusUnknown

This text of Heredia, Victoriano v. Blythe, Christopher (Heredia, Victoriano v. Blythe, Christopher) is published on Counsel Stack Legal Research, covering District Court, W.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Heredia, Victoriano v. Blythe, Christopher, (W.D. Wis. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN

VICTORIANO HEREDIA, DUJUAN NASH, JOSEPH OROSCO, BARNEY GUARNERO, BRIAN PHEIL, DONTAE DOYLE, JUMAR JONES, DENG YANG, on behalf of themselves and all others similarly situated,

Plaintiffs, v.

JOHN TATE II, Chairperson and Commissioner of the OPINION and ORDER Wisconsin Parole Commission; JENNIFER KRAMER, Commissioner of the Wisconsin Parole Commission; 19-cv-338-jdp DOUGLAS DRANKIEWICZ, Commissioner of the Wisconsin Parole Commission; KEVIN CARR, Secretary-Designee of the Wisconsin Department of Corrections; and ANGELA HANSEN, Director of the Bureau of Classification and Movement, in their official capacities,

Defendants.1

This is a class action that challenges how Wisconsin’s parole system applies to prisoners with very long sentences for crimes committed as juveniles. Plaintiffs’ claims are rooted in a line of Supreme Court decisions holding that the Eighth Amendment bars life sentences for most juvenile offenders. See Montgomery v. Louisiana, 136 S. Ct. 718 (2016); Miller v. Alabama, 567 U.S. 460 (2012); Graham v. Florida, 560 U.S. 48 (2010). Plaintiffs contend that implicit in these decisions is a constitutional right to meaningful parole consideration specifically on the basis of the prisoner’s maturity and rehabilitation, which Wisconsin’s parole system does not provide.

1 In their amended complaint, plaintiffs substituted John Tate II, Jennifer Kramer, and Angela Hansen for Steven Landreman, Danielle Lacost, and Mark Heise pursuant to Federal Rule of Civil Procedure 25. The Supreme Court has recently decided a new case that addresses life sentences for juvenile offenders: Jones v. Mississippi, 141 S. Ct. 1307 (2021). This court stayed discovery and asked the parties to explain whether Jones would foreclose any of plaintiffs’ claims. Dkt. 96; Dkt. 110.

For reasons explained below, Jones does not foreclose plaintiffs’ claims, but it does nothing to buttress plaintiffs’ arguments that the Constitution requires some specific mode of discretionary parole consideration for juvenile offenders. The court will not dismiss plaintiffs’ claims, but it will create subclasses for those convicted of homicide and those convicted of nonhomicide crimes to reflect the distinction that Jones recognizes between the two groups. The court will also lift the stay and decide plaintiffs’ two discovery motions, Dkt. 69 and Dkt. 92, which are fully briefed.

ANALYSIS

A. Effect of Jones In the order granting plaintiffs’ motion for class certification, the court summarized plaintiffs’ claims as follows: 1) Defendants are violating the Eighth Amendment by failing to give plaintiffs a meaningful opportunity for release based solely on plaintiffs’ demonstrated maturation and rehabilitation.

2) Defendants are violating the Due Process Clause by failing to adopt procedures that allow plaintiffs to demonstrate that they are entitled to release based solely on their maturity and rehabilitation.

3) Defendants are increasing plaintiffs’ mandatory minimum sentence in violation of the Sixth Amendment by denying parole on the ground that plaintiffs haven’t served enough time, even after plaintiffs reach their parole eligibility date.

4) Defendants are increasing plaintiffs’ maximum sentence in violation of the Sixth Amendment by implicitly finding that plaintiffs are “incorrigible” when defendants deny parole based on the amount of time served rather plaintiffs’ demonstrated maturity and rehabilitation.

Dkt. 53, at 3–4. Neither side challenges this summary. But plaintiffs now withdraw claim 4) because the evidence gathered in discovery doesn’t support it. Dkt. 97, at 4 and Dkt. 101, at 24. The court will dismiss that claim with prejudice. Plaintiffs’ Eighth Amendment and due process claims rest in large part on Montgomery, Miller, and Graham. In Graham, the Court held that the Eighth Amendment prohibits a juvenile offender convicted of a nonhomicide crime from being sentenced to life in prison without the possibility of parole. The Court stated that juvenile offenders must have “some meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation.” Graham, 560 U.S. at 75. In Miller, the Court issued a narrower holding for juvenile offenders convicted of homicide. The Court didn’t impose an outright ban on life sentences in that situation but held instead that a sentencing scheme that requires life without parole for juvenile offenders violates the Eighth Amendment. Miller, 567 U.S. at 465, 479. The sentencing court must be able to “consider[] an offender’s youth and attendant characteristics.” Id. at 483. In Montgomery, the Court held that Miller announced a substantive rule that has retroactive effect

in cases on collateral state review. In the orders screening the complaint, the court concluded that plaintiffs stated a claim under the Eighth Amendment by alleging that they were eligible for parole, but defendants were failing to provide a meaningful opportunity for release; plaintiffs stated a claim under the Due Process Clause by alleging that defendants were not providing the procedures necessary to allow plaintiffs to show that they were entitled to release; and plaintiffs stated a claim under the Sixth Amendment by alleging that defendants were increasing their mandatory minimum sentence based on facts not determined by a jury. Dkt. 3 and Dkt. 6. The question now before the court isn’t whether plaintiffs have proven any of their claims or are likely to succeed on them. Rather, the question is a narrow one: whether Jones forecloses any of the claims on which plaintiffs are proceeding. Plaintiffs’ remaining Sixth Amendment claim rests on cases such as Alleyne v. United

States, 570 U.S. 99 (2013), and is about the parole commission’s authority to find certain facts. It’s not based on Montgomery, Miller, or Graham, and the argument plaintiffs are making isn’t specific to juvenile offenders. So Jones has no implications for that claim. And Jones didn’t limit or even consider the scope of Graham, so it would have no effect on the claims of nonhomicide juvenile offenders.2 To determine the potential effect of Jones on the Eighth Amendment and due process claims of the class members convicted of homicide, the court starts with a closer look at Jones’s holding and reasoning. The Court began by summarizing the holding of Miller: “an individual

who commits a homicide when he or she is under 18 may be sentenced to life without parole, but only if the sentence is not mandatory and the sentencer therefore has discretion to impose a lesser punishment.” Jones, 141 S. Ct. at 1311. The question immediately before the Court was whether Miller and Montgomery prohibited a sentencing court from imposing a sentence of life in prison without parole on a juvenile offender convicted of homicide without first making an express or implicit finding that the offender was “permanently incorrigible.” Id. The Court concluded that no such express finding was required, holding that “a State’s discretionary sentencing system is both constitutionally necessary and constitutionally sufficient” to comply

2 The class definition is based on the length of a juvenile’s sentence rather than his conviction, so the class includes prisoners who were convicted of homicide and nonhomicide crimes. with Miller and Montgomery before sentencing a juvenile offender convicted of homicide to life without parole. Id. at 1313. Jones certainly does nothing to advance plaintiffs’ claims. And it provides support for a view that the standards governing juveniles convicted of homicide are not the same as the

standards governing juveniles convicted of homicide crimes.

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Heredia, Victoriano v. Blythe, Christopher, Counsel Stack Legal Research, https://law.counselstack.com/opinion/heredia-victoriano-v-blythe-christopher-wiwd-2021.