In re Murray

Citation: Not availableDocket: A161687A

Court: California Court of Appeal; August 31, 2021; California; State Appellate Court

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Paul Murray was sentenced to life without the possibility of parole (LWOP) for first-degree murder at age 22 in 2008. In 2020, he sought a hearing under People v. Franklin, arguing eligibility for a youth offender parole hearing as per Penal Code section 3051. The trial court denied his request, citing section 3051's exclusion of LWOP offenders who were 18 or older at the time of their offenses. Murray then filed a habeas corpus petition, claiming this exclusion violates his constitutional right to equal protection by allowing juvenile LWOP offenders a hearing while denying it to youthful offenders aged 18 to 25. Following an order from the California Supreme Court, the court issued an order to show cause regarding his claims. The respondent provided a return, and Murray submitted a traverse, with no oral arguments requested. Ultimately, the court denied the petition, determining there is a rational basis for the distinction between juvenile and youthful LWOP offenders regarding eligibility for youth offender parole hearings.

Section 3051 originated in 2013, driven by Eighth Amendment considerations regarding juvenile sentencing, particularly following key U.S. Supreme Court rulings such as Graham v. Florida and Miller v. Alabama, which highlighted the developmental differences between juveniles and adults. The California Legislature passed Senate Bill No. 260 to align juvenile sentencing with these decisions, emphasizing that youthfulness reduces moral culpability and increases the potential for rehabilitation. Initially, section 3051 only allowed parole eligibility hearings for juvenile offenders, excluding those sentenced to life without parole (LWOP). Over time, the Legislature expanded eligibility to include individuals who committed crimes at or before age 25, supported by scientific findings on brain development that indicate significant cognitive maturation continues into the mid-20s. Amendments in 2015 and 2017 progressively raised the age limit for parole eligibility, recognizing the ongoing maturation process and the development of decision-making capabilities.

The Legislature amended section 3051 to permit youth offender parole hearings for juveniles sentenced to life without parole (LWOP), aligning California law with the constitutional mandates established in Miller and Montgomery v. Louisiana, which retroactively prohibited mandatory LWOP sentences for juvenile offenders. This amendment aims to address unconstitutional juvenile LWOP sentences without requiring costly and lengthy resentencing hearings. Section 3051 differentiates between offenders under 18 and those aged 18 to 25, with the latter group excluded from parole hearings if sentenced to LWOP. Equal protection principles under the Fourteenth Amendment and California Constitution require that similarly situated individuals are treated equally unless justified otherwise. Courts evaluate equal protection claims by first determining if the classification affects similarly situated groups unequally and then assessing whether the classification serves a legitimate state purpose with a rational relationship. Statutory classifications are presumed rational unless a challenger provides no conceivable rationale for the unequal treatment. The rationale behind a classification does not need to be articulated or substantiated, merely rational.

The 'rational basis' scrutiny applied in this case is highly deferential, allowing laws to be upheld if any rational reason can be speculated for the differential treatment they create, regardless of empirical substantiation or legislative articulation. The petitioner claims that section 3051 violates equal protection by providing youth offender parole hearings to individuals sentenced to life without parole (LWOP) for offenses committed under 18, while denying this to those sentenced for offenses committed as adults. This claim is reviewed de novo and is ultimately found to lack merit. Even if juvenile and youthful LWOP offenders are considered similarly situated, the petitioner fails to show a lack of rational basis for the differing treatment. The Legislature's decision to grant parole eligibility based on age delineates between those under 18 and those 18 and older, a distinction upheld by both the U.S. and California Supreme Courts as rational in the context of criminal sentencing. Previous case law has rejected equal protection arguments based on similar age distinctions, affirming that the line between juveniles and adults remains rational. Concerns have been raised by several justices regarding the tension between section 3051 and evolving understandings of brain development, particularly for the 18-25 age group. While these concerns are acknowledged, they do not constitute an equal protection violation. The court emphasizes that it is not their role to question the law's wisdom or fairness but encourages legislative reconsideration of the age-based distinctions in section 3051 regarding youthful offenders. The petition for writ of habeas corpus is denied.