In three separate rulings, the Maryland Court of Special Appeals tossed out the life-without-parole sentences imposed against three men. The cases show the special circumstances that are involved in sentencing any youthful offender in a murder case. In each case, the offender was under 18 years old at the time of the crime, and, in each case, the sentencing judge did not do a meaningful analysis of the offender’s youth and potential for rehabilitation before issuing the sentences. Based upon recent decisions by the U.S. Supreme Court, a court may only sentence an under-18 offender to life without parole after first concluding that the offender’s acts showed a rare degree of “irreparable corruption.”
Each of the men who won their recent appeals had been convicted of first-degree murder. Aaron Holly, along with a 24-year-old man, was convicted in the shooting death of a Baltimore County woman in a botched robbery. Marcus Tunstall, while in the company of an older man, shot three people in a string of drug-related robberies. Kenneth Alvira and two 19-year-old men carjacked a woman. As part of the carjacking, the driver was stabbed and died from her wounds. Holly and Tunstall were 17 at the time of their crimes; Alvira was 16.