CONSTITUTIONAL LAW
Court of Appeals of Alaska (2024)
Lauren Beizer
In State of Alaska v. Fletcher, 555 P.3d 1046 (Alaska Ct. App. 2024), after the superior court ruled that a new constitutional rule applied retroactively, the court of appeals held that (1) the purpose of the new rule supported its full retroactive application; (2) the extent of reliance by law enforcement authorities on the old standard weighed against full retroactivity; (3) the minimal impact on the administration of justice from applying the new constitutional rule retroactively favored full retroactivity; and (4) the interests of crime victims have to be considered when determining if a new constitutional rule should apply retroactively to cases on collateral review. (Id. at 1046). In this case, Fletcher, who was 14 years old when convicted for both first-degree and second-degree murder, filed a post-conviction relief petition on the grounds that the sentence of 135 years constituted cruel and unusual punishment. (Id.). The case was originally dismissed on procedural grounds, but Fletcher appealed to which the court of appeals reversed in part and announced the new rule that a juvenile could only be sentenced if the court finds that the juvenile’s crime reflects “irreparable corruption.” (Id.). The court reasoned that interests of victims must be safeguarded and that it is possible for these rights to be upheld while also addressing the constitutional rights of juvenile offenders. (Id. at 1051). The court applied the three factors of the Judd test to affirm the superior court’s ruling in the Fletcher case (Id.).
