Must Court Explicitly Acknowledge Defendant's Youth When Imposing Life Sentence Without Chance of Parole?
Pursuant to U.S. Supreme Court's Decision in Miller v. Alabama
State of Ohio v. Eric Long, Case no. 2012-1410
First District Court of Appeals (Hamilton County)
ISSUE: Under the U.S. Supreme Court's 2012 holding in Miller v. Alabama, does a trial court violate the constitutional prohibition against cruel and unusual punishment if it imposes a sentence of life imprisonment without the possibility of parole for an aggravated murder committed by a juvenile without explicitly addressing in its sentencing order the youth of the defendant and the presumptions that minors are less culpable for criminal acts and are more amenable to rehabilitation than adults who commit similar offenses?