Dortch v. State

Tried, convicted and sentenced in 1994 as an adult, Dortch claimed at his Graham 2 resentencing hearing that a stipulation entered prior to his original trial — one he had never previously sought to enforce — remains binding and should now operate to limit his decades-old sentence. While his life without parole sentences in 1994 must be adjusted in light of Graham, the revivification of the abandoned stipulation is unjustified and the recasting of its purpose is contrary to principles of finality.

Dortch and the State stipulated prior to his first trial in January 1994 that the State need not…