17 Year Old Life Sentence In California
In People v. Dillon (1983) 34 Cal.3d 441, the California Supreme Court found the life sentence required for felony murder excessive under article I, section 17, as applied to a 17-year-old defendant.
The jury and the trial court concluded the defendant's culpability warranted a conviction and punishment less harsh than mandated by the "Procrustean" felony-murder rule. (Dillon, supra, 34 Cal.3d at pp. 477, 484-487.) the Supreme Court observed:
"The record fully supports the triers' conclusion. It shows that at the time of the events herein defendant was an unusually immature youth. He had had no prior trouble with the law, and, as in Lynch and In re Reed (1983) 33 Cal.3d 914 191 Cal. Rptr. 658, 663 P.2d 216, was not the prototype of a hardened criminal who poses a grave threat to society." (Dillon, supra, 34 Cal.3d at p. 488.)
In reducing the defendant's conviction to second degree murder, the court explained:
"The shooting in this case was a response to a suddenly developing situation that defendant perceived as putting his life in immediate danger.
To be sure, he largely brought the situation on himself, and with hindsight his response might appear unreasonable; but there is ample evidence that because of his immaturity he neither foresaw the risk he was creating nor was able to extricate himself without panicking when that risk seemed to eventuate." (Ibid.; see People v. Estrada (1997) 57 Cal.App.4th 1270, 1279 67 Cal. Rptr. 2d 596 noting defendant's state of mind as the "principal" factor under Dillon.)