Ohio Supreme Court Rules That Mandatory Sentences for Juveniles are Constitutional


The Ohio Supreme Court handed down their ruling stating that the state laws mandating juvenile sentences are constitutional on Wednesday, July 5.

The Court also ruled that longer penalties imposed for juveniles convicted at trial than for codefendants who pleaded guilty are not trial penalties.

Both rulings were handed down in the case of Rickym Anderson who was 16 at the time he was arrested and indicted on one count of kidnapping, on count of felonious assault and three counts of aggravated robbery. He was not found guilty of felonious assault, but was found guilty on the other counts and sentenced to 28 years in prison, later resentenced to 19 years.

Dylan Boyd, another minor who was arrested alongside Anderson in 2012, negotiated a plea that included his willingness to testify against Anderson if needed. He pleaded guilty to single counts of kidnapping, felonious assault and aggravated robbery with a firearm specification and received nine years in prison.

The Court based their ruling on mandatory juvenile sentences on the United States Supreme Court decision in Graham v. Florida (2010) and determined whether or not a penalty constituted cruel and unusual punishment, and whether there was a national consensus against the practice. They found that there is no national consensus against mandatory minimum sentences for juveniles, and in the Court’s opinion, Justice Terrence O’Donnell wrote that,

“[i]mposing a mandatory minimum sentence of three years on juvenile offenders for aggravated robbery and for kidnapping does not violate the Eighth Amendment’s prohibition against cruel and unusual punishment.”

However, this was not a unanimous decision. Both Chief Justice Maureen O’Connor and Justice William O’Neill agreed with the Court that Anderson’s sentence was not a trial tax, but dissented with the decision that juvenile mandatory minimums are constitutional. In Justice O’Neill’s dissent, he wrote that,

“The mandatory sentencing scheme, when applied to those who committed their crimes while juveniles, thwarts the right to individualized assessment by imposing a one-size-fits-all punishment.”

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