Chris Meadoux had not yet celebrated his 17th birthday when the state accused him of murdering Luis Martinez and Johnny You in 2007. The three boys had spent hours alone at a friend’s house. Then, Martinez and You were found dead in a burning house having sustained gunshot wounds and neck lacerations. After his arrest, Meadoux initially denied involvement.
Meadoux remained in custody, but when the officer interviewing him left the room to check on the technician responsible for taking the gunshot residue swab, Meadoux behaved like a teenager rather than a hardened criminal. He reached into the garbage, poured leftover soda on his hands, wiped them on his pants and jacket, and then used his teeth to attempt to scrape gunshot residue from his hands. His hands and clothes tested positive for gunshot residue anyway. After an hour and a half in custody, Meadoux gave a statement — the murders were accidents, he said.
The state charged Meadoux with capital murder, and a jury found him guilty. Because Meadoux was older than 14 but younger than 18, state law barred prosecutors from seeking the death penalty but allowed for a sentence of life without parole.
Meadoux’s case raises many hard questions. The ones heard during a hearing at the Texas Court of Criminal Appeals in Austin on Sept. 15 concerned his age.
Meadoux, who will turn 20 in a matter of days, is one of 19 or 20 (the number is disputed) inmates who committed their offenses as juveniles currently serving life without parole sentences in Texas. These state inmates are connected not because of their crimes but because of their age when they committed them.
Before 2005, state law allowed judges to sentence juveniles convicted of capital murder to life with parole after 40 years or the death penalty. But in 2005, the Legislature changed the law barring all (juvenile and adult offenders) from receiving parole. Then, in 2009, the Legislature revised the law again, this time barring juvenile offenders from being sentenced to life without parole. Unfortunately this legislative change of heart did not apply retroactively. This oversight is strikingly unfair.
The Legislature left Meadoux and the 19 or 20 other inmates in his situation frozen in a form of punishment that state law no longer condones. If a 17-year-old Meadoux had committed the crime two years later in 2009, no Texas judge could have sentenced him to life without the possibility of parole.
Should Meadoux be granted the possibility of parole retroactively? Yes. And is sentencing juveniles to life in prison a violation of the U.S. Constitution’s Eighth Amendment, which bars cruel and unusual punishment? This answer is less clear.
Meadoux’s attorney, Cheves Ligon of the Bexar County Public Defenders Office, attempted to answer these questions when he stood before the nine justices on the Texas Criminal Court of Appeals on Sept. 15.
Ligon based his arguments on science. He outlined the cognitive differences in the developing mind of a 16-year-old and the developed mind of an adult. Since 16-year-olds don’t have the right to vote, drive, marry with out parental consent or serve on juries because we doubt their judgment, Ligon said, why shouldn’t the same questions about a 16-year-old’s judgment apply in this case? However, that’s not the issue here. The Legislature already decided that 16-year-olds should be ineligible for life without parole. Instead, the issue is why this law doesn’t apply to those 19 or 20 inmates who are currently serving life without parole.
The state lawyer, J. Barrett Shipp, argued that the legislators acted intentionally when they declined to make the revision of law barring life without parole for juvenile offenders retroactive. Ultimately, to choose between sides in Meadoux’s case, the Texas Court of Criminal Appeals judges will have to weigh their empathy for a child who committed murder and determine if that empathy extends to believing the juvenile has a right as an adult to redeem his or herself so he or she might spend some of his or her adult life not behind bars — a right the Legislature had already extended to juvenile offenders going forward.
Although inherently muddy, the questions of a juvenile’s culpability require scientific discussion as much as they do legal analysis. But the Criminal Court of Appeals need not determine all the answers to those hard questions to justify ruling that Meadoux and his peers should benefit from the Legislature’s current stance; that is, the 2009 law prohibiting life without parole for a juvenile as cruel and unusual. Instead, simply by opting for equity — all the same rules apply for all offenders equally — the appellate judges should apply the 2009 law to Meadoux and the other inmates in his position.
