Hill v. Snyder

Since 2010, federal courts have been reviewing the punishments Michigan may impose on individuals convicted of first-degree murder for acts they committed as children. In the meantime, the Supreme Court has twice ruled that the unique characteristics of youth must factor into sentencing decisions for juvenile offenders facing life imprisonment. Michigan has amended its statutory scheme to implement these rulings. On remand, the district court considered a Second Amended Complaint (SAC), asserting that Michigan’s sentencing scheme and parole system deny youth offenders a meaningful opportunity for release. The court determined that jurisprudential concerns barred Plaintiffs’ claims and dismissed. The Sixth Circuit affirmed in part. The claim based on Michigan statutory law, which has been amended, is moot. Declining to apply “Younger” abstention, the court reasoned that finding that the filing of the SAC required reconsideration of jurisdiction “would both expand and warp an otherwise cabined and clear doctrine.” One claim was properly dismissed under the “Heck” doctrine: a declaration that sentences of life without parole for juvenile offenders are unconstitutional would necessarily implicate the duration of impending sentences and is not cognizable under 42 U.S.C. 1983. Claims that seek an examination of “policies and procedures governing access to prison programming and parole eligibility, consideration and release” and that the retroactive elimination of Plaintiffs’ accrued good time credits violates the Ex Post Facto Clause should not have been dismissed. View "Hill v. Snyder" on Justia Law