Life sentence enhancement based on juvenile prior does not violate the cruel and unusual clause of the Constitution

The defendant in U.S. v. Hoffman was sentenced to life for his conviction of conspiracy to distribute of 50 or more grams of methamphetamines in violation of 21 U.S.C. §§ 841(a)(1), 846, and with possession with intent to distribute methamphetamines. Prior to trial on these federal crimes the government filed a notice pursuant to 21 U.S.C. §851 that it intended to seek enhance punishment base on a prior Florida state drug convictions for conspiracy to traffic in cocaine and possession of cocaine. His priors were committed at 17, and at the time, he was sentenced as a youthful offender. The prior Florida felony drug convictions increased the minimum from 10 years to life imprisonment and at sentencing the district court imposed a life sentence. On appeal, the defendant challenged the life sentence under the Eighth Amendment arguing the sentence was cruel and unusual punishment because the basis for the punishment were the two conviction for offenses committed while the defendant was a juvenile.

Defendant relied on the Supreme Court decision in Roper v. Simmons where the court held that the 8th and 14th amendments forbid imposing the death penalty on offenders who were under the age of 18 when their crimes were committed. The 11th Circuit found Roper did not apply and distinguished it on these grounds:
1. Roper involved a death sentence and not a life imprisonment.
2. Roper did not involve a juvenile prior uses as a sentencing enhancement for an adult offender.

In an earlier case, the 11th Circuit had rejected a challenge to the use of youthful offender convictions under the career offender sentencing guidelines and the Armed Career Criminal Act because it found Roper does apply to sentencing enhancement cases. “Roper does not mandate that we wipe clean the records of every criminal on his or her eighteenth birthday.” In two prior cases the 11th Circuit had held that mandatory life enhancement provision of §851, for defendants having two or more prior felony drug offenses, does not violate the Eighth Amendment.

The 11th Circuit also rejected the defendant’s argument that Miller v. Alabama made the sentence illegal. In Miller the Supreme Court prohibited a mandatory life-without-parole-sentence for defendants who were under the age of 18 when they committed the crime. Miller was distinguished by the court because it involve a juvenile offender facing punishment for a crime committed as a juvenile and focused on the reasons why it would be cruel and unusual for a juvenile to face a mandatory life sentence. The 11th Circuit found nothing in Miller that said an adult offender who committed the crimes while a juvenile should not receive a mandatory life sentence as an adult after committing the crime as an adult. Miller did not deal with enhancements and the court found a difference between enhancing a juvenile offender to a life sentence and considering youthful offenses when sentencing an offender to life who continues criminal activity into adulthood.

The court also rejected the defendant’s challenge to the reasonableness of the sentence. Though the district court stated that it had considered the §3553(a) factors, the district court was statutorily required to impose a life sentence regardless of the factors.