Court: ‘3 strikes’ life sentences can count juvenile crimes

February 7, 2022 GMT

TRENTON, N.J. (AP) — A crime committed as a juvenile can be considered for sentencing an adult to life without parole under New Jersey’s “three strikes” law, a split state Supreme Court ruled Monday.

The case involved a man who had committed armed robbery while he was 16 then committed two additional armed robberies when he was 23. Samuel Ryan was sentenced to life without parole after conviction on the third robbery under the 1995 state law that mandates that sentence for repeat offenders convicted of certain types of violent crimes.

Ryan appealed his sentence on the grounds that recent court rulings by the U.S. Supreme Court and New Jersey Supreme Court have held that mandatory sentences of life without parole for juvenile offenders are unconstitutional and constitute cruel and unusual punishment.

In denying his appeal, a 4-2 majority on Monday wrote those rulings don’t support his case and cited several federal appeals courts around the country that have ruled similarly.


In a dissent joined by Justice Fabiana Pierre-Louis, Justice Barry Albin wrote the majority’s decision “is at odds with the evolving standards of decency addressed in our federal and state constitutional caselaw.”

As an example, he noted that last month, the state Supreme Court held that juveniles convicted of murder and sentenced to mandatory minimum terms of 30 years without parole can seek a review of their sentence once they’ve served 20 years.