In a case involving first-degree murder committed by a juvenile, the Tennessee Supreme Court has clarified that a defendant convicted of first-degree murder committed on or after July 1, 1995, and sentenced to life in prison becomes eligible for release after serving a minimum of 51 years in prison.
Cyntoia Denise Brown, who was 16 years of age at the time, was transferred from juvenile court and tried as an adult in criminal court for the first-degree premeditated murder and first-degree felony murder of Johnny Allen, in addition to another charge. A jury convicted Ms. Brown of the murder charges. The trial judge merged the two murder convictions and sentenced her to life in prison for those convictions. The Court of Criminal Appeals affirmed Ms. Brown’s murder convictions and life sentence on direct appeal and in collateral proceedings.
Ms. Brown subsequently filed a petition for writ of habeas corpus in the United States District Court for the Middle District of Tennessee in which she alleged that her mandatory minimum sentence of life imprisonment constitutes cruel and unusual punishment prohibited under precedent set forth by the Supreme Court of the United States in Miller v. Alabama. The District Court denied relief because the Miller opinion prohibits a mandatory sentence of life without the possibility of parole for juvenile offenders, and Ms. Brown received a life sentence, not a sentence of life without the possibility of parole. Ms. Brown appealed that decision to the United States Court of Appeals for the Sixth Circuit.
The Sixth Circuit requested the Tennessee Supreme Court to answer the question of whether a defendant convicted of first-degree murder committed on or after July 1, 1995, and sentenced to life in prison will become eligible for release and, if so, after how many years of imprisonment. Tennessee Supreme Court Rule 23 permits the Court to answer requests that involve questions of Tennessee law that are determinative of the cause of action and about which there is no controlling Tennessee precedent.
In today’s unanimous decision, the Tennessee Supreme Court explained that, under state law, a life sentence is a determinate sentence of 60 years. However, the sixty-year sentence can be reduced by up to 15 percent, or 9 years, by earning various sentence credits. Therefore, the Supreme Court concluded that a defendant serving a life sentence for a first-degree murder committed on or after July 1, 1995, may be eligible for release after serving at least 51 years of the sentence.