Alejandro Estrada-Huerta, Petitioner v. the People of the State of Colorado, Respondent

Summary

The court affirmed the denial of post-conviction relief, holding that the constitutional protections discussed in Graham and Miller do not apply to an aggregate term-of-years sentence imposed for multiple offenses. Because Estrada-Huerta received consecutive terms of years rather than a sentence of life without parole, his forty-years-to-life sentence was not invalidated on that ground. Justice Gabriel, concurring in the judgment, would have applied the relevant protections to de facto life-without-parole sentences but would still have affirmed because Estrada-Huerta was eligible for parole within his life expectancy.