The Pennsylvania Supreme Court framed the issue: “Whether a discretionary term-of-years sentence may be so long as to amount to a de facto life sentence, thereby triggering the substantive and procedural protections afforded by Miller v. Alabama and its progeny.” The Court applied the United States Supreme Court’s recent holding in Jones v. Mississippi, which severely narrowed the holdings of Miller and Montgomery v. Louisiana. The Pennsylvania Supreme Court concluded that its decision in Commonwealth v. Batts (Batts II) has been mostly abrogated. The Court held that “pursuant to the reasoning in Jones, even if a term-of-years sentence amounts to a de facto life sentence, Miller provides no viable avenue for relief.”
