On June 26, 2017, the Pennsylvania Supreme Court reversed a Pennsylvania Superior Court’s decision which affirmed the lower court’s decision to sentence a 14 year old boy to life imprisonment without parole.  See Commonwealth of Pennsylvania v. Qu’eed Batts.

Qu’eed Batts (Batts) was convicted of first degree murder that he committed when he was 14 years old.  He was sentenced to life in prison without the possibility of parole.

At the trial that took place in July 2007, Batts’ defense was that he shot the victims under duress in fear that a gang member would kill him.  He was convicted of first degree murder, attempted murder and aggravated assault.  Batts was sentenced to a mandatory term of life in prison without the possibility of parole.  Batts subsequently appealed his sentence, but his appeal was denied.

Batts later appealed to the Pennsylvania Supreme Court arguing that his sentence was illegal as it violates the U.S. Supreme Court’s decisions in 2 cases that held a juvenile sentenced to life with no parole is unconstitutional.  See Miller v. Alabama, 567 U.S. 460 (2012), and Montgomery v. Louisiana, 136 S.Ct. 718 (2016).

Related: The Effect of the U.S. Supreme Court’s Montgomery Decision on PA Inmates Convicted of Murder [Two Supreme Court cases provide hope for juveniles sentenced to life without parole.  Many cases may be remanded for sentencing.]

In life sentence appeals, the PA Supreme Court does not usually consider the details of an offender’s personal history and past. However, in the Batts case, the court delved into Batt’s traumatic background and found that the details of his childhood should have been considered when determining his sentence.

At a young age, Batts was shuffled from foster home to foster home.  He was beaten by foster parents, victimized sexually by an older cousin and abandoned by his mother.  At age 11, he lived in a homeless shelter.  He frequently got into fights because children would tease him about his situation.  He dealt with issues of abandonment. Despite all this, he performed well in school and excelled in several sports.  However, when he was in middle school, Batts met a member of the Bloods gang.   The gang member told Batts that the gang was a family group that took care of each other, which Batts found enticing.  Batts then became involved with the gang and sold drugs for them.  Click here to see the court’s full opinion and recitation of Batts’ history.

On the night of the incident, Batts was in a vehicle with several gang members.  One of them had previously killed three other people, and he instructed Batts to shoot 2 people in another car.  According to Batts, he shot the victims because he was afraid that the gang member would kill him if he didn’t comply.

Batts was charged as an adult, and his lawyer requested to transfer the case to juvenile court.  Despite his age, the trial court held that Batts failed to prove that the public interest would be served by moving the matter to juvenile court and rejected defense expert testimony that Batts could be rehabilitated.

After considering all of the facts and evidence provided by both sides, the Supreme Court held that Batts’ life sentence without parole was unconstitutional.  In addition, the court held that pursuant to Miller, life without parole is only justified for “the rare juvenile offender who exhibits such irretrievable depravity that rehabilitation is impossible.”  See Montgomery.  The Commonwealth must meet its burden, beyond a reasonable doubt, that life without parole is justified.  The Supreme Court found that the Commonwealth did not meet its burden and reversed the Superior Court’s decision of affirming Batts’ sentence of life in prison without parole.

Appealing Life Sentences Without Parole

Mr. Nenner has extensive criminal trial experience and has been selected by Super Lawyers as a “Top Rated Criminal Defense Attorney in Philadelphia, PA.”  Mr. Nenner always offers FREE initial consultations. 215.564.0644

Related Philadelphia Criminal Homicide Case Results

• Philadelphia Criminal Lawyer, David Nenner, Helps Man Wrongly Accused of Murder (March 2017) – Mr. Nenner’s client was arrested for a murder he did not commit and spent 17 months in jail waiting for trial. However, due to Mr. Nenner’s investigation, he uncovered crucial evidence which challenged the DA’s theory that his client was the shooter.
• Mr. Nenner secured the release of his client after serving two years in jail for a murder he did not commit. Video evidence showed that Mr. Nenner’s client was in a different location when the homicide occurred.
• Mr. Nenner obtained an acquittal for his client who was accused of attempted murder, aggravated assault and various firearm offenses. At trial, Mr. Nenner was able to show that the victim had previous lied to the police and the Grand Jury.