For the first time, the Minnesota Supreme Court has agreed to let a juvenile murderer fight his mandatory life sentence without parole on the grounds that it’s unconstitutional.
The case involves Mahdi Ali, who was 16 when he killed three men during a January 2010 robbery at Minneapolis’ Seward Market. Under state law, Ali’s first-degree premeditated murder conviction called for a life sentence without parole, even in the case of a juvenile certified to stand trial as an adult.
In June 2012, the U.S. Supreme Court ruled in Miller vs. Alabama, a case involving a 14-year-old boy, that sentencing juveniles to life in prison without considering their youth, motive and potential for rehabilitation violated the U.S. Constitution’s prohibition on cruel and unusual punishment.
The ruling didn’t ban life without parole for juveniles, but said a judge must consider mitigating circumstances before imposing such a harsh penalty. Minnesota had eight juvenile killers in prison for life without parole before the high court issued its ruling.
Chuck Samuelson, executive director of the American Civil Liberties Union of Minnesota, hailed the ruling, saying he believes it’s wrong to mandate that a juvenile be put in prison for life.
“Is it slightly possible that the person you are when you are 17 won’t be the same person you will be later in life?” he asked. “Your body and mind changes. I think the court got it right.”
While Wednesday’s ruling is sure to change the way state courts handle subsequent juvenile cases calling for mandatory life sentences, it will have little impact on Ali’s sentence. For the three murders, he received the mandatory life sentence without parole and two life sentences with parole eligibility in 60 years, which the state Supreme Court didn’t vacate.
Ali killed an employee of Seward Market, his relative and a customer as they begged for their lives. Several others also were convicted in the murders.
Ali’s case now will be remanded to Hennepin County District Court for a “Miller hearing” to consider factors such as the emotional issues that impact a juvenile, his family and home environment, and the circumstances of the homicide, including peer pressure. The District Court could still rule that he deserves life without parole or determine a new sentence of life with the possibility of parole after serving a minimum of 30 years in prison.
Deputy Hennepin County Attorney Dave Brown said he was pleased with Wednesday’s ruling. In the wake of the U.S. Supreme Court’s decision, there is no question that the state’s mandatory punishment for juveniles convicted of premeditated murder is unconstitutional, he said.
Brown said it’s too early to tell if his office will lobby the Legislature to change the “heinous crimes” statute, which requires the mandatory life sentence. It has been discussed over the years with the state’s county attorney association, law enforcement and other interested parties, he said.
Samuelson said he doubts that legislators will change the state’s mandatory sentencing law because they may fear that voters will call them soft on crime.
Ali’s attorney, Lydia Villalva Lijo, suggested in her argument before the Minnesota Supreme Court in June that the Legislature should change the life-sentence law. She couldn’t be reached for comment Wednesday.
Sentences under scrutiny
In recent months, state supreme courts in Illinois, Iowa, Massachusetts and Texas have ruled that inmates serving life terms for juvenile crimes should receive new sentencing hearings.
Since May 2013, the Minnesota Supreme Court has ruled on two other mandatory juvenile life sentence cases handed down in the state, both times rejecting arguments for changing sentences. They were appealed long before the U.S. court’s Miller decision. In 1996, 17-year-old Timothy Chambers stole a car and led police on a chase that ended when he slammed into a squad car, killing a Rice County sheriff’s deputy. In 2000, 17-year-old Tony Roman Nose raped and stabbed a teen to death.
All seven justices agreed with the majority ruling that mandatory juvenile life sentences without parole are unconstitutional. Justices Alan Page and David Stras also wrote opinions stressing that the court didn’t have the right to overrule a sentence required by the Legislature or to find the mandatory statute unconstitutional and order the District Court to impose life with parole.
In its ruling, the state Supreme Court wrote that it faced a sentencing scheme that didn’t comply with the new rule of constitutional criminal procedures announced in the Miller ruling and that the Legislature has remained silent on how to fix it. The justices said they could completely ignore the current mandatory sentence or “do the least amount of damage to the statutory scheme” by sending it back to District Court for resentencing following a Miller hearing.
In his individual response, Page wrote that because the state’s sentencing scheme is a matter of law, the court lacks the power to authorize a Miller hearing. He suggested that the court should have ordered the District Court to impose a sentence of life with parole after 30 years.
Stras said he agreed with many of Page’s points, but added that the state Constitution requires the court to sever an unconstitutional provision and enforce those remaining portions of the statute that don’t violate U.S. or state constitutions.