State of Minnesota v. Jason Ryan Williams

862 N.W.2d 701, 2015 Minn. LEXIS 254, 2015 WL 2088883
CourtSupreme Court of Minnesota
DecidedMay 6, 2015
DocketA14-1640
StatusPublished
Cited by3 cases

This text of 862 N.W.2d 701 (State of Minnesota v. Jason Ryan Williams) is published on Counsel Stack Legal Research, covering Supreme Court of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Minnesota v. Jason Ryan Williams, 862 N.W.2d 701, 2015 Minn. LEXIS 254, 2015 WL 2088883 (Mich. 2015).

Opinion

OPINION

WRIGHT, Justice.

Following a jury trial, the district court convicted and sentenced appellant Jason Ryan Williams for two counts of first-degree murder, one count of attempted first-degree murder, and one count of burglary. We affirmed Williams’s convictions on direct appeal. State v. Williams, 535 N.W.2d 277, 279 (Minn.1995).

In May 2014, Williams moved to correct his sentence, citing Miller v. Alabama, — U.S. —, 132 S.Ct. 2455, 2469, 183 L.Ed.2d 407 (2012) (holding that mandatory imposition of life imprisonment without the possibility of release (LWOR) for juvenile offenders who are sentenced as adults violates the Eighth Amendment). The *702 postconviction court denied the motion, rejecting Williams’s arguments that the rule announced in Miller should be extended to statutory provisions that mandate the imposition of life imprisonment with the possibility of release and should apply to a district court’s discretionary imposition of consecutive sentences that Williams characterizes as functionally equivalent to life imprisonment without the possibility of release. Because the postconviction court’s decision is consistent with our recent rulings, including Ouk v. State, 847 N.W.2d 698, 701 (Minn.2014), and State v. Ali, 855 N.W.2d 235, 257-58 (Minn.2014), we affirm.

I.

Williams’s convictions arose from the offenses he committed on October 12, 1992, when he was 16 years old. 1 Williams entered a home in Brooklyn Park, killed a mother and her three-year-old daughter, and severely injured her four-year-old son.

Following a jury trial, the district court entered judgments of conviction for two counts of first-degree premeditated murder, one count of attempted first-degree premeditated murder, and one count of burglary. 2 The relevant statutory scheme mandated life imprisonment with the possibility of release after 30 years for the first-degree murder convictions. Minn. Stat. § 244.05, subd. 4 (1994). The presumptive penalties for the attempted murder and burglary convictions were, respectively, an executed sentence of 180 months’ imprisonment and a stayed sentence of 21 months’ imprisonment. See Minn. Sent. Guidelines IV (1994). Under Minn. Sent. Guidelines II.F.2 (1994), it was within the district court’s discretion to impose consecutive sentences. Based on the existence of two aggravating sentencing factors, the district court determined that the appropriate sentence for the attempted murder conviction was 240 months’ imprisonment. The district court imposed a mandatory sentence of life imprisonment with the possibility of release for each first-degree murder conviction, a sentence of 240 months’ imprisonment for the attempted murder conviction, and a sentence of 18 months’ imprisonment for the burglary conviction. The district court ordered each sentence to be' served consecutively, resulting in an aggregate sentence of at least 74 years in prison. 3 Williams appealed his convictions, arguing that the district court prejudicially erred by admitting evidence of his confession. Williams, 585 N.W.2d at 279. We affirmed Williams’s convictions. Id.

Nineteen years later, on May 14, 2014, Williams moved to correct his sentence under Minn. R.Crim. P. 27.03, subd. 9, 4 *703 based on the rule announced by the United States Supreme Court in Miller, — U.S. at —, 132 S.Ct. at 2469. Under Miller, statutory provisions that mandate the imposition of an LWOR sentence for juvenile offenders sentenced as adults violate the Eighth Amendment to the United States Constitution because they preclude judicial consideration of an offender’s youth and attendant characteristics. — U.S. at —, 132 S.Ct. at 2468-69. Williams argued that the rule announced in Miller should apply both to statutory provisions that mandate the imposition of life imprisonment with the possibility of release and to the imposition of consecutive sentences that are the functional equivalent of life imprisonment without the possibility of release. The postconviction court denied Williams’s motion. This appeal follows.

II.

We review a postconviction court’s denial of a motion to correct a sentence for an abuse of discretion. Ouk, 847 N.W.2d at 701 (citing Townsend v. State, 834 N.W.2d 736, 738 (Minn.2013)). A postcon-vietion court “abuses its discretion when its decision is based on an erroneous view of the law or is against logic and the facts in the record.” Riley v. State, 792 N.W.2d 831, 833 (Minn.2011).

Williams argues that we should apply the rule announced in Miller to a mandatory sentence of life imprisonment with _the possibility of release. We disagree. As we explained in State v. Vang, because a mandatory sentence of life imprisonment with the possibility of release after 30 years is “not tantamount to a death sentence” when applied to a juvenile offender, it “does not constitute cruel and unusual punishment under the Eighth Amendment and the principles of Miller.” 847 N.W.2d 248, 262-63 (Minn.2014). This determination also is consistent with our ruling in Ouk that a mandatory sentence of life imprisonment with the possibility of release after 30 years “does not violate the rule announced in Miller because it does not require the imposition of the harshest term of imprisonment: life imprisonment without the possibility of release.” 847 N.W.2d at 701. Williams has not articulated, nor can we discern, any reason to depart from our holdings in Vang and Ouk.

Williams also seeks to extend the rule announced in Miller to a district court’s discretionary imposition of consecutive sentences that, as he contends, are the functional equivalent of life imprisonment without the possibility of release. We decline to do so. As we explained in Ali, the statutory provision mandating the imposition of an LWOR sentence was the crucial factor in Miller because it prevented consideration of the defendant’s youth. 855 N.W.2d at 258. Unlike the mandatory LWOR sentehces in Miller, the decision to impose concurrent or consecutive sentences rests within the discretion of the district court. Minn.Stat. § 609.15, subd. 1(a) (2014); see State v. Warren, 592 N.W.2d 440

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Related

Williams v. State
476 P.3d 805 (Court of Appeals of Kansas, 2020)
State v. Ali
895 N.W.2d 237 (Supreme Court of Minnesota, 2017)
State of Minnesota v. Arthur Charles Huffman
Court of Appeals of Minnesota, 2016

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Bluebook (online)
862 N.W.2d 701, 2015 Minn. LEXIS 254, 2015 WL 2088883, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-minnesota-v-jason-ryan-williams-minn-2015.