Jedlicka v. State

Seth D. Jedlicka v. State of Maryland No. 30, September Term 2021 Criminal Procedure – Constitutional Law – Juvenile Offenders – Life Sentences. In Carter v. State,

461 Md. 295

(2018), the Court set forth a test for determining whether a lengthy term-of-years sentence with a significant period of parole ineligibility is a de facto sentence of life without the possibility of parole, which the Eighth Amendment forbids for juvenile non-homicide offenders. Under that test, an aggregate 60-year sentence with parole eligibility after 25 years is not a de facto life sentence. Criminal Procedure –…