A nearly maximum adult sentence for a 13-year-old’s murder conviction was an outlier needing leavening, the Court of Appeals of Indiana ruled in a Thursday reversal.
A unanimous panel of appellate judges partially reversed in Alphonso L. James, III v. State of Indiana, 21A-CR-148, concluding Alphonso James III’s 63-year sentence for fatally shooting an 18-year-old acquaintance “that matches the harshest sentences imposed on hardened adult offenders” was too severe.
James was 13 when he killed Jaren Minies during an Xbox, money and firearm trade in September 2018. While inside a vehicle during the exchange, James reached for Minies’ gun while also drawing his own weapon and shot Minies nine times.
James, who fled to New York, was adjudicated in 2019 as a delinquent for additional crimes and committed to a juvenile detention center for 18 months before being returned to Indiana to face delinquency proceedings in Minies’ murder.
The Indiana juvenile court waived jurisdiction and James was ultimately charged and prosecuted for murder as an adult.
Rather than placing James in a juvenile facility per his request, the Elkhart Circuit Court found him guilty and sentenced the minor to 63 years in prison — two years shy of the max for adult murderers.
The COA concluded that treating James the same as an adult offender for sentencing purposes “not only is illogical” but also “contravenes the basic notion in our law ‘that juveniles are different from adults when it comes to sentencing and are generally less deserving of the harshest punishments.’”
“We conclude that Alphonso’s sentence was inappropriate in light of the nature of the offense and the character of the offender,” Judge Leanna Weissmann wrote.
The Court of Appeals cited Legg v. State, 22 N.E.3d 763, 767 (Ind. App. 2014), trans. denied, as instructive in determining a proper sentence for James. It ultimately remanded to the trial court for entry of a 55-year sentence.
The COA, however, found no abuse of discretion in the trial court’s denial of James’ request for alternative juvenile sentencing or in its consideration of unadjudicated or unadmitted allegations of juvenile offenses as aggravating circumstances.
It noted the trial court concluded James did not qualify for alternative sentencing, his offense was “heinous and aggravated” and the “most serious of [his] pattern of delinquent acts,” and that he was beyond rehabilitation under the juvenile justice system. It further noted that the community’s safety and welfare were served by sentencing James as an adult.
Finally, as to the aggravating circumstances, the appellate court disagreed with James’ contention that the trial court blurred the line between adjudicated and unadjudicated juvenile allegations.