Commonwealth v. Lee, D., Aplt.

Summary

The court held that mandatory life imprisonment without parole for every Pennsylvania felony-murder conviction does not violate the federal Eighth Amendment because the relevant federal categorical precedents concern capital punishment or juvenile offenders. It nevertheless held that the Pennsylvania Constitution provides broader protection and prohibits imposing mandatory life without parole without an individualized assessment of culpability. The judgment was reversed, the sentence vacated, and the case remanded for resentencing, with the order stayed for 120 days to allow legislative consideration. Justices Wecht, Dougherty, and Mundy concurred with additional reasoning or scope limitations, while Justice Brobson concurred in part and dissented in part regarding the breadth and adequacy of the remedy.