DENNIS LEBLANC v. RANDALL MATHENA, Chief Warden, Red Onion State Prison, Pound, Virginia; COMMONWEALTH OF VIRGINIA
US Court of Appeals for the Fourth Circuit,Wynn , Nov. 7, 2016,
Juvenile Life-Imprisonment – Virginia’s “Conditional release of geriatric prisoners” statute does not meet the Graham standard requiring “meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation” for non-homicide juvenile life-sentences.
Dissent – Niemeyer – Virginia’s implementation is not unreasonable and should receive deference under federal habeas corpus review
Reversed by the Supreme Court
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