Eleventh Circuit

Loggins v. Thomas, 654 F.3d 1204 (11th Cir. 2011). State court properly resentenced juvenile defendant to life without parole for murder in light of the Supreme Court’s Roper v. Simmons decision finding the Eighth and Fourteenth Amendments prohibit imposing the death penalty on offenders who were under age 18 when they committed their crimes. Contrary to juvenile’s argument, there is not a clear consensus that life without parole is an inappropriate punishment for juveniles. Over 40 states still impose life sentences on juveniles for murder.

United States v. Nagel, 2016 WL 4547169 (11th Cir.). Defendant appealed 292-month sentence imposed after he pleaded guilty to three counts of enticement of minor to engage in sexual activity, challenging its procedural and substantive reasonableness. Trial court correctly not did group separate counts because conduct underlying each count caused separate and distinct harm to victim and did not impose sentence greater than necessary to comply with statutory goals of sentencing.