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Chandler v. State

Supreme Court of Mississippi, En Banc

March 8, 2018

JOEY MONTRELL CHANDLER a/k/a JOEY M. CHANDLER a/k/a JOEY CHANDLER
v.
STATE OF MISSISSIPPI

          DATE OF JUDGMENT: 10/09/2015

         CLAY COUNTY CIRCUIT COURT TRIAL HON. JAMES T. KITCHENS, JR. JUDGE.

          TRIAL COURT ATTORNEYS: CARRIE A. JOURDAN KATIE NICOLE MOULDS SCOTT WINSTON COLOM.

          ATTORNEYS FOR APPELLANT: OFFICE OF THE STATE PUBLIC DEFENDER BY: ERIN ELIZABETH BRIGGS GEORGE T. HOLMES.

          ATTORNEY FOR APPELLEE: OFFICE OF THE ATTORNEY GENERALBY: LISA L. BLOUNT.

          DISTRICT ATTORNEY: SCOTT WINSTON COLOM.

          COLEMAN, JUSTICE.

         ¶1. In 2005, Joey Montrell Chandler was convicted for the murder of his cousin Emmitt Chandler and sentenced to life in prison under Mississippi Code Section 97-3-21 (2005). The Court affirmed his conviction and sentence on appeal. Chandler v. State, 946 So.2d 355, 356, 366 (¶¶ 1, 54) (Miss. 2006). In 2015, Chandler received a new sentencing hearing for his murder conviction in light of the United States Supreme Court's decision in Miller v. Alabama, 567 U.S. 460 (2012). Following the hearing, the circuit court sentenced Chandler to life in prison. Chandler appeals, requesting that he be resentenced because the trial court failed to analyze all the factors identified in Miller and adopted in our subsequent decision in Parker v. State, 119 So.3d 987 (Miss. 2013).

         FACTS AND PROCEDURAL HISTORY

         ¶2. In 2014, Chandler filed a petition with the Court claiming that he was entitled to resentencing in light of the United States Supreme Court's decision in Miller. We granted Chandler permission to file a motion to set aside his sentence in light of Miller. On January 8, 2015, the trial court held a hearing on the matter in which it allowed Chandler to present evidence in support of his motion.

         ¶3. On October 9, 2015, the trial court entered a detailed, six-page order. The trial court recounted what the evidence showed at Chandler's trial. Chandler had been selling because his girlfriend was pregnant and he needed to earn money to help pay for expenses. Chandler observed his cousin Emmitt exiting Chandler's vehicle with Chandler's marijuana. The next day, Chandler armed himself and confronted Emmitt. Chandler shot Emmitt two times with a pistol and the wounds were lethal. Chandler disposed of the murder weapon by throwing it in a pond.

         ¶4. At the time of the murder, Chandler was seventeen years, six months, and thirteen days old. Upon resentencing, the trial court found that Chandler's actions on the day of the murder showed premeditation, planning, and an attempt to dispose of the murder weapon. Noting that the victim was not armed, the trial court described the murder as "heinous" under the facts of the case.

         ¶5. The trial court's order included a discussion of Miller and our subsequent cases applying Miller, including Parker and Jones v. State, 122 So.3d 698 (Miss. 2013). The trial court's order verified that it had reviewed the transcripts of the case, the court file, and Chandler's presentence investigation report. After carefully reviewing the evidence in the case and the matters presented in the resentencing hearing, the trial court found that Chandler should be sentenced to life in prison for the murder of his cousin Emmitt.

         STANDARD OF REVIEW

         ¶6. The Court has yet to review a trial court's sentencing decision under Miller. Chandler argues that the Court should review the trial court's decision with the same "heightened scrutiny" that applies in death-penalty cases, because a sentence of life without parole is the harshest punishment that can be imposed on a juvenile offender. See Bennett v. State, 990 So.2d 155, 158 (Miss. 2008) ("The standard of review of convictions for capital murder and sentences of death is 'heightened scrutiny.'"). Accordingly, Chandler contends that all doubts as to the appropriateness of the trial court's decision must be resolved in his favor. In contrast, the State argues that the trial court's imposition of a criminal sentence is reviewed for an abuse of discretion. See Hampton v. State, 148 So.3d 992, 999 (Miss. 2014).

         ¶7. Heightened scrutiny is reserved for death-penalty cases due to the unique and irreversible nature of that punishment. The Court has no reasonable basis to raise its standard of review for a sentence in a noncapital case simply because it involves a juvenile offender. Accordingly, we hold that there are two applicable standards of review in a Miller case. First, whether the trial court applied the correct legal standard is a question of law subject to de novo review. Smothers v. State, 741 So.2d 205, 206 (Miss. 1999). If the trial court applied the proper legal standard, its sentencing decision is reviewed for an abuse of discretion. Hampton, 148 So.3d at 999.

         DISCUSSION

         ¶8. Chandler argues that the trial court failed to address all of the sentencing considerations mandated by Miller and Parker. Thus, the issue on appeal is whether the trial court comported with the requirements of Miller and Parker when resentencing Chandler to life in prison for a murder which he had committed when he was seventeen years old. In short, we hold that the trial court comported by applying the correct legal standard because it afforded Chandler a hearing and sentenced Chandler after considering and taking into account each factor identified ...


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