Jonas David Nelson v. Minnesota

This Court’s “cases establish that the ‘narrow proportionality’ review applicable to noncapital cases … takes the personal ‘culpability of the offender’ into account in examining whether a given punishment is proportionate to the crime,” Graham v. Florida, 560 U.S. 48, 90 (2010) (Roberts, C.J., concurring), and that “all but the rarest of juvenile offenders” are ineligible for sentences of life in prison without the possibility of release, Montgomery v. Louisiana, 136 S. Ct. 718, 734 (2016). Petitioner, who was 18 years and 7 days old on the night he killed his abusive father and likely suffered from both cognitive deficits and mental illness that may have caused the crime, sought a hearing where he could prove that his automatic sentence of life without the possibility of release violates the Eighth Amendment. The postconviction court denied petitioner a hearing, and a divided Minnesota Supreme Court affirmed over two dissents. The questions presented are:

1. Whether the Eighth Amendment right to narrow proportionality review of sentences of life without release entails a right to a hearing at which evidence may be presented sufficient to sustain a claim of gross disproportionality.

2. Whether the Eighth Amendment or Equal Protection Clause guarantees defendants who are just barely chronological adults a hearing at which evidence may be presented sufficient to sustain a claim that they are materially indistinguishable from juveniles for Eighth Amendment purposes. (i)