PC Archives - OCCA Opinions

PC-2018-723

Post author:Staff
Post published:September 5, 2019
Post category:PC

**Summary of Court Decision: Shawn A. Detwiler v. The State of Oklahoma** *Case Overview:* Shawn A. Detwiler sought post-conviction relief related to multiple convictions stemming from offenses committed as a juvenile, including armed robbery and shooting with intent to kill. After initially pleading guilty to several charges and receiving concurrent sentences, he argued that the combination of his consecutive sentences constituted a de facto life without parole sentence, violating his Eighth Amendment rights. *Key Points of Rulings:* 1. **Case Summation:** Detwiler was convicted on several counts involving crimes such as burglary, robbery, and assault. His sentences ranged from 5 years to life imprisonment, some being discharged over time. 2. **Legal Precedents Cited:** Detwiler's argument was heavily reliant on the legal interpretations established in *Graham v. Florida*, *Miller v. Alabama*, and *Montgomery v. Louisiana*, which emphasize that juvenile offenders should not be sentenced to life without parole for non-homicide crimes. 3. **District Court's Findings:** The District Court found that since Detwiler was not sentenced to life without parole or its functional equivalent, the Eighth Amendment protections cited in those cases did not apply. 4. **Aggregate Sentencing Argument:** Detwiler contended that his sentences, when viewed collectively, equated to a de facto life sentence. However, the court maintained that each sentence should be evaluated independently. 5. **Response to Tenth Circuit Precedent:** The Oklahoma Court of Criminal Appeals referred to a prior ruling (Martinez v. State) which rejected the idea of viewing multiple sentences in aggregate for Eighth Amendment analysis. 6. **Conclusion by the Court:** Detwiler's post-conviction relief was ultimately denied. The court established that he has the potential for parole consideration and has not received sentences that deal with him as if he was sentenced to life without parole as per the noted precedents. *Dissenting Opinions:* 1. Judge Lewis dissented, arguing that consecutive sentences for multiple serious offenses committed as a juvenile effectively mean a lifetime sentence without a realistic chance for release, which may constitute cruel and unusual punishment. 2. The dissent emphasized that juveniles should be given a chance to demonstrate maturity and rehabilitation, which the current sentencing practices do not permit. 3. It was asserted that the framework of Graham should extend to prevent the imposition of excessively punitive aggregated sentences for juveniles, thereby relieving them of permanent confinement without the chance for parole. *Final Notes:* The court's ruling underscores ongoing debates about sentencing juveniles, the interpretation of constitutional protections, and the lengths of sentences impacting juvenile offenders. The dissent highlights the critical need for opportunities for rehabilitation and review in cases involving young individuals.

PC 2017-755

Post author:Staff
Post published:May 24, 2019
Post category:PC

In OCCA case No. PC 2017-755, the petitioner appealed his conviction for First Degree Murder. In a published decision, the court decided to vacate the previous sentence and allow for resentencing with a jury. The dissenting opinions argued against the majority decision, indicating that the judge had the discretion to deny jury resentencing based on prior waivers. The case started when the petitioner was just seventeen years old and pleaded guilty to First Degree Murder in 2006. Originally, he was sentenced to life in prison without the chance for parole. After some time, he claimed that this sentence was unfair because he was a minor when he was sentenced. The court agreed and decided to let him be resentenced but had to deal with the issue of whether his resentencing should involve a jury. The petitioner argued that since he was seeking resentencing, he should be allowed a jury trial. However, the state disagreed, pointing out that he had waived his right to a jury trial when he originally pleaded guilty. The judge decided that because of this waiver, he didn’t have to give the petitioner a jury for resentencing. In this case, the court looked at previous decisions that said when a juvenile is sentenced to life without parole, they should have a jury trial unless they give up that right. The majority of the court found that the petitioner did not truly waive his right to a jury for the resentencing, as he was relying on new rules from recent important cases. Ultimately, the court decided that it was wrong for the judge to deny the jury resentencing. They chose to vacate that decision and said the case should go back to the lower court to figure out the right way to do the resentencing, with the ability to include a jury if the petitioner asked. The dissenting opinions argued that the judge had actually acted correctly by denying the request for a jury because the petitioner had already waived that right back when he pleaded guilty. They believed that the rules shouldn’t allow a person to change their mind long after the original decision. The court ordered that the petitioner’s guilty plea and conviction were still valid, but they needed to follow the correct process under the law for the new sentencing.

PC-2015-6

Post author:Staff
Post published:December 3, 2015
Post category:PC

In OCCA case No. PC-2015-6, Kendall Wayne Edwards appealed his conviction for First Degree Murder. In a published decision, the court decided to affirm the lower court's ruling that granted post-conviction relief, vacating Edwards's murder conviction and ordering a new trial based on claims of ineffective assistance of counsel and newly discovered evidence. One judge dissented. The case stemmed from an incident on March 9, 2001, where Edwards was accused of shooting Gerald Lamont Ford during a fight outside a convenience store. Edwards was convicted at trial and sentenced to life imprisonment, but he sought post-conviction relief in 2012, claiming several errors occurred during his trial, including improper admission of evidence and ineffective legal representation. The court's analysis focused primarily on the newly discovered evidence claim, which was that another witness, Larika A. Alexander, could potentially exonerate him by stating she saw him being beaten and heard the gunshot without witnessing him fire the weapon. The lower court agreed that this evidence was significant enough to undermine confidence in the outcome of the trial and held that Edwards deserved a new trial. While the majority opinion supported this conclusion, a dissenting judge argued that the new evidence did not sufficiently meet the standard required to warrant a new trial since it was cumulative and lacked materiality. The dissent emphasized that the jury had already evaluated the credibility of the witnesses during the original trial. Ultimately, the court's decision to uphold the lower court's granting of a new trial was based on the notion that justice required the possibility of a different outcome with this new testimony. Thus, Edwards was granted the opportunity for a re-examination of the case.

PC 2006-0638

Post author:Staff
Post published:February 28, 2007
Post category:PC

In OCCA case No. PC 2006-0638, the petitioner appealed his conviction for manufacturing a controlled dangerous substance, possession of counterfeit bills, and larceny by fraud. In an unpublished decision, the court decided to reverse the lower court's denial of post-conviction relief and ordered a new trial due to ineffective assistance of counsel. One judge dissented. The petitioner had previously been convicted by a jury and sentenced to prison along with fines. After the conviction, the petitioner argued that his trial and appellate lawyers did not perform effectively. He contended that many mistakes were made during his trial, impacting the fairness of his case. The trial court found that the petitioner's attorney did not challenge the way his statement to the police was obtained, which was a significant part of the evidence used against him. The lawyer also failed to ask for important jury instructions and did not properly raise issues on appeal. The trial court agreed that the lawyer made many mistakes, but initially decided that these mistakes did not change the outcome of the case. However, upon review, the appellate court determined that the mistakes made by the lawyer were so serious that they undermined confidence in the trial's outcome. This meant that the petitioner did not get a fair trial, violating his rights. The decision was reversed, and the case was sent back to the lower court for a new trial. This case highlights the importance of having effective legal representation, as mistakes made by lawyers can lead to wrongful convictions or unfair trials.