Brown v. Hobbs

Summary

The court affirmed dismissal of Brown’s habeas petition because his life sentence for first-degree murder was discretionary rather than mandatory. The court held that the constitutional rule concerning juvenile life-without-parole sentences applies when the sentencing scheme mandates that punishment without permitting consideration of youth and mitigating circumstances, which did not occur here. Brown therefore failed to show that his commitment was facially invalid or that the sentencing court lacked jurisdiction.