Hicklin v. Schmitt
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The Supreme Court affirmed the judgment of the circuit court against Jessica Hicklin in a declaratory judgment action against Eric Schmitt, Missouri's attorney general and other State parties, holding that Hicklin's claims were without merit.
Hicklin asserted in her complaint that her 1997 life-without-parole sentence for first-degree murder was invalid following the United States Supreme Court's decisions in Miller v. Alabama, 567 U.S. 460 (2012), and Montgomery v. Louisiana, 136 S. Ct. 718 (2016). The Supreme Court disagreed, holding (1) challenges to the constitutional validity of Missouri statutes are properly brought in a declaratory judgment action; (2) Missouri's General Assembly can accept the Supreme Court's invitation to remedy Miller-affected sentences by supplying parole eligibility; and (3) the Parole Board's authority does not violate the separation of powers.
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