People v. Washington

Defendant, age 19 at time of offense, pled guilty to murder of a homeless man beaten to death by Defendant and 2 codefendants. Court sentenced Defendant to 32 years. No case precedent extends the Miller v. Alabama decision to an offender who was not a juvenile or sentenced to a natural or de facto life sentence. No case precedent has concluded that a nonlife sentence for a nonjuvenile offender violated the proportionate penalties clause on the basis of the defendant's developing brain. Defendant did not raise an arguable claim that his guilty plea was involuntary.  (DeARMOND and HOLDER WHITE, concurring.)