Recent SCOTUS Decision Does Not Retroactively Apply to Juvenile Plea Bargain

A plea bargain entered by a defendant to avoid the death penalty as a juvenile is not retroactively affected by a Supreme Court decision that found juvenile death sentences to be unconstitutional

Dingle v. Stevenson, 2016 BL 354573, 4th Cir., No. 15-6832, 10/25/16.

The Fourth Circuit did not expand the scope of the Supreme Court’s decision in Roper v. Simmons, 543 U.S. 551 (2005) to retroactively apply to defendants who entered into plea deals to avoid the death penalty as juveniles. In the original case, the defendant avoided a possible death penalty or life sentence without parole by entering into a plea deal while he was still seventeen. The defendant argued that his plea was involuntary because he was threatened with what is now considered an unconstitutionally cruel and unusual punishment. The court, however, found that his guilty plea and subsequent sentence were entirely unrelated to the Supreme Court’s decision. The court stated that “[A]lthough Roper, in hindsight, altered the calculus underlying Dingle's decision to accept a plea agreement, it does not undermine the voluntariness of his plea.”  The Supreme Court’s decision only applies if the defendant is actually sentenced to death or life without parole.

http://www.bloomberglaw.com/public/document/Dingle_v_Stevenson_No_156832_2016_BL_354573_4th_Cir_Oct_25_2016_C.