Bear Cloud v. State

Defendant entered guilty pleas to aggravated burglary, first-degree murder, and conspiracy to commit aggravated burglary. Defendant was sentenced to life imprisonment on the first-degree murder conviction. At the time of the murder, Defendant was a juvenile. The Supreme Court affirmed, holding that Defendant's sentence of life imprisonment for first-degree murder, mandated by Wyo. Stat. 6-2-101(b), was constitutional. After that decision, the U.S. Supreme Court issued Miller v. Alabama, where it held that the Eighth Amendment forbids a sentencing scheme that mandates life in prison without the possibility of parole for juvenile offenders. Based on Miller, Bear Cloud petitioned for certiorari to the U.S. Supreme Court. The U.S. Supreme Court granted the petition, vacated the judgment in Bear Cloud I and remanded the case to the Wyoming Supreme Court. On remand, the Court held that, in light of the Miller decision, Bear Cloud's sentence for his first-degree murder conviction violated the Eighth Amendment and related U.S. Supreme Court case law. Remanded with instructions to resentence Bear Cloud on the first-degree murder conviction. View "Bear Cloud v. State" on Justia Law