William Shaun Walker v. North Carolina

In Miller v. Alabama, 567 U.S. 460 (2012), this Court held that the Eighth Amendment forbids mandatory LWOP sentences for juvenile defendants convicted of first-degree murder. Later, this Court held in Jones v. Mississippi, 593 U.S. 98 (2021), that trial judges are not required to make a finding of irreparable corruption before imposing LWOP in Miller cases. However, this Court made clear that its holding in Jones did not involve as-applied disproportionality arguments. After Miller and Jones, courts are fractured on how to resolve as-applied disproportionality arguments in Miller sentencing appeals. Some jurisdictions grant virtually unbridled discretion over the imposition of LWOP sentences. See State v. Ramirez, 990 N.W.2d 550 (Neb. 2023). Other jurisdictions enforce the proportionality principle at the heart of Miller and reverse LWOP sentences imposed in cases where the defendant is not irreparably corrupt. See People v. Bennett, 966 N.W.2d 768 (Mich. 2021). Some jurisdictions have developed still other approaches. This case presents an ideal vehicle for resolving the question of how as-applied disproportionality claims in Miller sentencing cases should be resolved on appeal because Mr. Walker was sentenced to LWOP despite presenting voluminous evidence that he is not irreparably corrupt. This case thus presents the following question: Whether as-applied disproportionality arguments in Miller sentencing cases should be resolved on appeal based on the standard of irreparable corruption as described in the key paragraph in Montgomery v. Louisiana, 577 U.S. 190 (2016), or left entirely in the discretion of trial judges? -i-