Edward Pinchon v. Raymond Byrd, Warden
HabeasCorpus Punishment
Whether the Sixth Circuit erred in concluding that the Miller v. Alabama holding applies only to sentences expressly articulated as life without the possibility of parole
QUESTION PRESENTED At age 17, Edward Pinchon was convicted of first-degree murder for the killing of a middle-aged man who was sexually abusing him. Tennessee law mandated that he receive a sentence of at least “life.” Tennessee courts have interpreted this “life” sentence to entail service of a sentence of 60 years, which can be reduced to 51 years by earning good-time credits. Did the Sixth Circuit err in (a) concluding that the Miller v. Alabama, 567 U.S. 460 (2012) held merely that sentences expressly articulated as life without the possibility of parole violate the Eighth Amendment when imposed, pursuant to mandatory sentencing schemes, against juvenile offenders, and (b) thereby holding that the state court decision denying Pinchon relief was not “contrary to” Miller and that Pinchon was thus not entitled to habeas relief under 28 U.S.C. § 2254(d)? i