United States Fourth Circuit

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Malvo v. Mathena, 17-6746

Affirmed: The juvenile offender of the DC Beltway sniper duo was convicted of capital murder for crimes committed when he was 17 years old. He was sentenced to 4 terms of life imprisonment without parole. After his conviction and sentence the US Supreme Court held that persons who committed serious crimes when under 18 could not be sentenced to death and that they could not be sentenced to life imprisonment unless the offenses reflected permanent incorrigibility and that these rules applied retroactively. Because of the new rules, the district court vacated the life sentences without parole and remanded for re-sentencing. The 4th Circuit affirmed.

Appellate Information

  • Decided
  • Published 2018/06/21


  • Niemeyer


  • United States Fourth Circuit


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