A convicted murderer who was 16 years old when he berated police and the judicial system for unjustly pinning a popular Prosser man's death on him and locking him up for life now may have a chance at freedom.
Jose Angel Munguia, now 30, was one of about 30 Washington cases affected Monday by a U.S. Supreme Court decision to throw out mandatory life sentences without parole for juveniles.
His is the only case out of Benton-Franklin Superior Court.
The 5-4 ruling by the nation's highest court concluded that a mandatory sentencing rule that sends teenage convicted killers to prison without possibility of parole amounted to cruel and unusual punishment, in violation of the Constitution's Eighth Amendment.
It was in response to appeals from two cases in Alabama and Arkansas, in which the defendants both were 14 years old when they committed their crimes.
Munguia was 15 in July 1997 when he shot Guivi Darbeliani three times in the head and dumped him in an irrigation canal after trying to rob the 27-year-old immigrant. The Grandview teen claimed self-defense, but a Benton County jury a year later convicted him of aggravated first-degree murder.
Superior Court Judge Vic VanderSchoor had no option under Washington law but to sentence Munguia to the maximum life term.
Now, Munguia -- who is at Clallam Bay Corrections Center on the Olympic Peninsula -- can file a motion to be resentenced in light of Monday's ruling.
Benton County Prosecutor Andy Miller isn't happy, but says he was prepared for the justices to go either way.
"Ever since the U.S. Supreme Court accepted review ... it's been an issue percolating that people have been talking about," Miller told the Herald. "We're disappointed in that we thought (Munguia) needs to be held accountable. We thought it was clearly a premeditated crime. On the other hand, I'm not surprised" with the majority opinion.
The decision does not mean Munguia will get a new trial.
However, what isn't clear is whether the sentencing judge can send Munguia back to prison for life. The ruling left open the possibility that an individual judge might have discretion to impose life without parole if he or she thinks it is an appropriate sentence given the circumstances, Miller said.
In Munguia's case, the jury made a finding of aggravated murder because of the robbery motive. That could be enough for the sentencing judge to order an exceptional sentence, above the standard range as it was in 1998 for first-degree murder of 20 to 27 years, Miller said.
At his sentencing in July 1998, Munguia insisted he was not a murderer and said he was shocked that for going to police to try to straighten things out he ends up spending life behind bars.
Munguia claimed at trial that he shot Darbeliani because the older man appeared ready to attack and rape him and two friends. He also accused local police of being anti-Hispanic.
However, Miller said Munguia and his accomplices, brothers Valentin and Ricardo Sanchez, lured Darbeliani into a remote orchard near Prosser to rob him of his sports car. Prosecutors told jurors that Darbeliani did nothing to provoke Munguia or anyone else.
Darbeliani was a popular teacher's aide and community volunteer.
The Sanchez brothers both pleaded guilty to second-degree murder.
A list of cases, as compiled by the Washington Association of Prosecuting Attorneys, that likely will be affected by Monday's decision also includes Barry Loukaitis.
In February 1996, the 14-year-old Moses Lake boy walked into his Frontier Middle School algebra class, pulled a rifle from under his black trench coat and opened fire. He killed a teacher and two fellow students and critically wounded a third classmate.
His 20 convictions included two counts of aggravated first-degree murder, and he was sentenced to two life terms plus almost 205 years.
"In imposing a state's harshest penalties, a sentencer misses too much if he treats every child as an adult," Justice Elena Kagan wrote for the majority. "Mandatory life without parole for a juvenile precludes consideration of his chronological age and its hallmark features; among them, immaturity, impetuosity and failure to appreciate risks and consequences."
The American Bar Association lauded the high court's finding that it is unconstitutional to lock up forever a youth for a murder conviction.
"We are gratified that the court followed its precedents ... in determining that juvenile offenders are constitutionally different from adults for sentencing purposes," ABA President Wm. T. (Bill) Robinson III said in a written statement. "Juveniles are less morally culpable and more capable of rehabilitation than adults convicted of the same crimes."
The ABA filed briefs with the Supreme Court in support of reversing the life sentences for Evan Miller of Alabama and Kuntrell Jackson of Arkansas.
Robinson further wrote that the association has long maintained giving juveniles the chance at parole doesn't compromise public safety or the objectives of punishment.
"While not all juveniles will be able to establish that they should be granted parole, they should not be denied the opportunity to be considered for parole before they die in prison," he said.
Currently, more than 2,500 individuals are serving life without parole for murders committed when they were under 18. About 2,100 of them were convicted in states where they faced mandatory life sentences; these are the inmates who now have the chance to secure their freedom.
"What the majority is saying is that members of society must be exposed to the risk that these convicted murderers, if released from custody, will murder again," Justice Samuel Alito declared.
Alito underscored his unhappiness by reading his dissent at length from the bench. Chief Justice John Roberts Jr. added his own written dissent, arguing that the court should leave such sentencing policy decisions up to state legislatures.
-- The Tri-City Herald's Washington, D.C., bureau contributed to this report.
-- Kristin M. Kraemer: 582-1531; firstname.lastname@example.org