Ray Hobbs in His Capacity as Director of the Arkansas Department of Correction, Appellant v. Barry Turner, Appellee

Summary

The court affirmed both the State’s direct appeal and Turner’s cross-appeal. It held that Arkansas law did not authorize a sentence of life imprisonment with the possibility of parole, so the circuit court properly replaced Turner’s unconstitutional life-without-parole sentence with the statutory maximum of forty years. The court also held that Graham did not require additional individualized consideration of Turner’s youth or a sentence below the statutory maximum in this limited habeas proceeding, and that Miller was inapplicable because Turner was a juvenile nonhomicide offender.