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Supreme Court reverses circuit court decision for procedural error

[JURIST] The US Supreme Court on Monday overturned [text, PDF] the Fourth Circuit's decision, concluding that the Virginia state court did not unreasonably apply the court's decision from Graham v. Florida [text, PDF]. Under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) [text], "a state prisoner is eligible for federal habeas corpus relief if the underlying state court merits ruling was 'contrary to, or involved an unreasonable application of, clearly established Federal law.'" The Supreme Court's ruling in Graham held that a juvenile prisoner may not be sentenced to life without parole for non-homicide offenses, without a "some meaningful opportunity to obtain release." The state court found that Dennis LeBlanc, convicted of rape at age 16, was provided a reasonable opportunity under Virginia's "geriatric release" program, "which allows older inmates to receive conditional relase under some circumstances." Under the AEDPA, the Fourth Circuit Court reversed the state court decision, finding it an unreasonable application of the Graham decision. In a per curiam opinion, the Supreme Court overturned the circuit court's ruling, stating:

The Court of Appeals for the Fourth Circuit erred by failing to accord the state court's decision the deference owed under AEDPA. Graham did not decide that a geriatric release program like Virginia's failed to satisfy the Eighth Amendment because that question was not presented. And it was not objectively unreasonable for the state court to conclude that, because the geriatric release program employed normal parole factors, it satisfied Graham's requirement that juveniles convicted of a non-homicide crime have a meaningful opportunity to receive parole.

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