People v. Cisneros

Justice ERICKSON

specially concurring:

I join the majority opinion in its entirety and agree with the underlying conclusion that a defendant’s age is irrelevant in determining whether a sentence is proportionate to a crime under the Eighth Amendment of the United States Constitution. Maj. op. at 828. I write separately to emphasize that our resolution of these cases is dictated by United States Supreme Court decisions addressing the Cruel and Unusual Punishment Clause of the Eighth Amendment.

*831Under the structure of our national system, a state court decision interpreting the federal Constitution is of course no less authoritative than a lower federal court decision. Lockhart v. Fretwell, — U.S. -, -, 113 S.Ct. 838, 846, 122 L.Ed.2d 180 (1993) (Thomas, J., concurring); Steffel v. Thompson, 415 U.S. 452, 482 n. 3, 94 S.Ct. 1209, 1227 n. 3, 39 L.Ed.2d 505 (1974) (Rehnquist, J., concurring). The Supreme Court, however, is the final judicial interpreter of the federal Constitution. Cooper v. Aaron, 358 U.S. 1, 78 S.Ct. 1401, 3 L.Ed.2d 5 (1958); Lujan v. Colorado State Bd. of Educ., 649 P.2d 1005 (Colo.1982).

As such, a state court is bound by Supreme Court precedent interpreting the federal Constitution and cannot impose greater limitations or afford more protections under the federal Constitution than the Supreme Court has in its decisions. Oregon v. Hass, 420 U.S. 714, 719, 95 S.Ct. 1215, 1219, 43 L.Ed.2d 570 (1975); see, e.g., Minnesota v. Clover Leaf Creamery Co., 449 U.S. 456, 461-63 n. 6, 101 S.Ct. 715, 722-23 n. 6, 66 L.Ed.2d 659 (1981); Fare v. Michael C., 442 U.S. 707, 717, 99 S.Ct. 2560, 2567, 61 L.Ed.2d 197 (1979); North Carolina v. Butler, 441 U.S. 369, 376, 99 S.Ct. 1755, 1759, 60 L.Ed.2d 286 (1979); accord People v. Berger, 185 Colo. 85, 88-89, 521 P.2d 1244, 1245 (1974); American Fed’n of Labor v. Reilly, 113 Colo. 90, 96, 155 P.2d 145, 148 (1944); Wilcox v. People, 46 Colo. 382, 384, 104 P. 408, 409 (1909); Smith v. Farr, 46 Colo. 364, 370, 104 P. 401, 403 (1909). Nor can a state court dictate a restriction as a matter of federal constitutional law that the Supreme Court has specifically refrained from imposing. Hass, 420 U.S. at 719, 95 S.Ct. at 1219.

In Harmelin v. Michigan, — U.S. -, 111 S.Ct. 2680, 115 L.Ed.2d 836 (1991), Justice Scalia, writing for the majority, specifically refrained from requiring individualized sentencing for noncapital cases. See id. at -, 111 S.Ct. at 2702 (“[w]e have drawn the line of required individualized sentencing at capital cases, and see no basis for extending it further”). Following the Supreme Court’s decision in Harmelin, it would contradict the axiomatic principles of Hass to interpret the Eighth Amendment as requiring consideration of mitigating factors such as the defendant’s age in a noncapital case.