The Pennsylvania Superior Court has ruled in a high-profile murder case that the state Supreme Court's landmark 2017 decision raising the prosecutorial burden for seeking a life without parole sentence for a juvenile offender should not be applied retroactively.
In a precedential Dec. 19 ruling in Commonwealth v. Stahley, a three-judge panel of the Superior Court ruled 2-1 to uphold a Montgomery County trial court's dismissal of defendant Tristan Stahley's Post-Conviction Relief Act petition.
Stahley had argued that the Supreme Court's ruling last year in Commonwealth v. Batts (known as Batts II) retroactively rendered his sentence of life without parole illegal.
In Batts II, the Supreme Court unanimously determined that courts should have a presumption against imposing sentences of life without parole (LWOP) for juveniles, and that, to overcome that presumption, prosecutors will need to prove beyond a reasonable doubt that the offender is incapable of being rehabilitated.
The Batts II decision was a reaction to two U.S. Supreme Court rulings: Miller v. Alabama from 2012, which imposed a ban on mandatory LWOP sentences for juveniles, and Montgomery v. Louisiana from 2016, which made Miller retroactive.
Stahley argued that the Batts II decision presented a new rule of law that was retroactively applicable to his PCRA claim. The new rule, Stahley contended, barred LWOP sentences from being imposed on a defined class of individuals: those whom prosecutors cannot prove beyond a reasonable doubt are incapable of rehabilitation.
The Superior Court majority, led by Judge Correale Stevens, disagreed with that premise, however.
"It was Miller, not Batts II, that announced the relevant substantive rule requiring retroactive application when it held sentencing a juvenile to life without parole is excessive for all but 'the rare juvenile offender whose crime reflects irreparable corruption,'" Stevens said. "Indeed, the Pennsylvania Supreme Court specifically announced it was providing with its Batts II decision a procedural overlay to Miller in order to advance implementation of Miller. As such, Batts II did not represent an extension of Miller by defining an additional class of juvenile offenders capable of rehabilitation and, thus, insulated from LWOP sentencing. Instead, it only developed procedures, rooted in Miller’s principal considerations of juvenile sentencing, that would optimize accurate identification of rehabilitable juveniles coming under Miller’s protection."
The Superior Court majority also rejected Stahley's alternative argument that Batts II established a "'watershed rule of criminal procedure requiring retroactive application.'"
Stevens said Batts II established a procedural scheme aimed at reducing misapplications of Miller, but did not alter the bedrock principles of Miller.
"Rather than including Batts II among the ranks of Gideon v. Wainwright—the only
decision recognized by the United States Supreme Court as issuing a watershed procedural rule—we understand Batts II as announcing a new rule that nevertheless rests largely on the Miller precedent," Stevens said.
Stahley was convicted of first-degree murder and sentenced to LWOP for stabbing his ex-girlfriend, Julianne Siller, when he was 16, according to Stevens' opinion. The case garnered widespread media attention in Pennsylvania.
In addition to his Batts II arguments, Stahley also argued in his PCRA appeal that his defense lawyer had rendered ineffective assistance by failing to introduce evidence of Stahley's intoxication at the time of the murder.
The Superior Court rejected that contention as well.
"Most problematic for appellant is that the evidence he presents to sustain his claim does not show he was 'so intoxicated as to be overwhelmed to the point of losing his faculties and sensibilities and unable to formulate a specific intent to kill,'" Stevens said, citing language from the 2012 state Supreme Court case Commonwealth v. Spotz. "In fact, the testimonies of those who saw appellant shortly before and shortly after the murder in question indicate he ably
directed his actions and communicated his thoughts during all relevant times. Though he was emotional that evening, he nevertheless demonstrated no difficulty in leading investigators to the crime scene, describing to authorities the events leading up to his killing of Ms. Siller, or confirming that he formed the intent to kill just seconds before he stabbed her. Such evidence, therefore, refutes appellant’s claim that counsel’s failure to make a voluntary intoxication presentation denied him a worthwhile guilt-phase defense."
Stevens was joined in full by Judge Victor Stabile.
Senior Judge Eugene Strassburger filed a concurring and dissenting opinion, saying that while he agreed with the majority's rejection of Stahley's ineffective assistance of counsel claims, he would have found Batts II retroactively applicable to Stahley's case.
"Batts II prohibits punishment against a class of persons, i.e. those juveniles whom the commonwealth has not proven beyond a reasonable doubt to be permanently incorrigible," Strassburger said.
Marsha Levick of the Juvenile Law Center in Philadelphia is representing Stahley and could not be reached for comment.
A spokeswoman for the Montgomery County District Attorney's Office declined to comment except to say the office was pleased with the Superior Court's decision.
(Copies of the 14-page opinion in Commonwealth v. Stahley, PICS No. 18-1587, are available at http://at.law.com/PICS.)