People v. Palafox

Luis Palafox was a juvenile when he and Kyle Hoffman committed two burglary-murders for which they were each sentenced to two consecutive life terms. On appeal, the California Court of Appeals vacated and remanded their cases for resentencing with express orders that the trial court render a new decision in light of Miller v. Alabama. On remand, after considering the Miller factors, the trial court found that the greater weight of the circumstances and severity of the crime outweighed any mitigating Miller factors that might counsel against life without parole for the defendants. Accordingly, the trial court again resentenced Palafox to life without parole. The Court of Appeals affirmed this resentencing.

Juvenile Law Center filed an amicus letter supporting Palafox’s petition to the California Supreme Court for review of the lower court’s resentencing. Our letter argued that the California Supreme Court should adopt a presumption in favor of immaturity and against imposing life without parole upon juvenile offenders. For juveniles convicted of homicide, the presumption in favor of immaturity and against life without parole must be afforded great weight lest the sentencer's focus on the loss of life in each case render Miller meaningless. We also argued that the California Supreme Court should review the case in order to give lower courts further guidance on how to sentence in cases similar to Palafox’s; failure to give this guidance could result in the arbitrary imposition of life without parole on juvenile offenders. Finally, we argued that the Court should review Palafox’s sentence since the case raises important questions as to what weight sentencers must attach to a juvenile offender’s potential for rehabilitation.

The California Supreme Court denied the petition for review.