A Port St. Lucie man, who is serving two life sentences for bludgeoning his parents to death with a hammer in 2011 when he was 17, will have a chance to argue that he should one day be allowed to live outside prison walls.
As it has done for others convicted of committing heinous crimes when they were under 18, the 4th District Court of Appeal on Wednesday ruled Tyler Joseph Hadley, now 22, should benefit from a 2012 U.S. Supreme Court decision that outlawed life sentences without parole for juveniles. The youths deserve special consideration because their brains aren’t fully developed, act impetuously and they are amenable to rehabilitation, the high court ruled.
In response to the ruling, the Florida Legislature passed a law that allows life sentences for juveniles. But, a judge must make certain findings, the West Palm Beach-based court found.
Because Hadley was sentenced in 2014, before the law went into effect, 19th Judicial Circuit Judge Robert R. Makemson had no way of following it, the appeals court wrote. While crediting the judge for trying his best, it said he erred by justifying the life sentence by saying Hadley had a previously been convicted of a capital crime. There is no evidence of that, the court wrote. Further, Makemson was required to consider possible alternatives to a life sentence.
Almost apologetically, the appeals court wrote: “We are therefore compelled to reverse and remand for resentencing.” Under the law, the minimum sentence would be 40 years and any sentence would be reviewed after 25 years.
The murders attracted national attention because of their brutality and callousness. After killing his parents, Hadley had a keg party, locking their bloodied bodies in a bedroom.