State v. Ryan

This case presented the New Jersey Supreme Court with the confluence of several hot-button issues: Miller & Zuber, New Jersey’s three-strikes law, and a youthful offender now serving life without the possibility of parole. Here, the defendant committed his first armed robbery when he was 16 years old, and then at the age of 23, he committed two more — his second and third strikes. He argued that modern sentencing jurisprudence forbids courts from counting crimes committed while under the age of eighteen as predicate offenses in sentencing defendants to mandatory life without parole. The Supreme Court held that a defendant’s prior juvenile-age conviction counts as a predicate offense under the Three Strikes Law. And such a procedure is not cruel and unusual punishment.

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