Missouri judge rejects inmate claims that sentencing decision was illegal
Deandra Buchanan, an inmate at the Jefferson City Correctional Center serving a first degree murder sentence for killing his girlfriend and two others in 2000 (Rudi Keller/Missouri Independent).
A Missouri man serving life without parole on Monday lost a bid to reopen his criminal case for an in-person resentencing he claims he was unconstitutionally denied.
Deandra Buchanan, convicted in Boone County of three counts of first-degree in 2002, was originally sentenced to death. The Missouri Supreme Court reduced the sentence to life without parole in 2003.
The statute allowing the court to directly resentence people sentenced to death violates another law, and federal court precedent, requiring defendants to be present when their sentence is pronounced, Buchanan argued through public defender Tyler Coyle.
When the Supreme Court found the death sentence to be unconstitutional in Buchanan's case, the trial court should have brought him in for in-person resentencing.
But Boone County Circuit Judge Jeff Harris disagreed, deciding that the high court was within its authority when it changed Buchanan's sentence. Harris didn't address the constitutional questions raised by Buchanan.
'Because the Supreme Court exercised its authority to resentence defendant, there was no need and basis for the circuit court to take any further action or hold a resentencing hearing,' Harris wrote.
The ruling isn't a setback, Coyle said, because he and Buchanan had expected a definitive ruling would come from an appeals court.
'The state argued at our in-person hearing that if we have a problem with what the Supreme Court did, we should be asking the Supreme Court,' Coyle said. 'That's what the prosecutor argued to Judge Harris. It kind of sounds like by not addressing that part of it, that's what is left for us to do now.'
In his final brief in the case, Coyle wrote that the question is analogous to the issue decided by the Missouri Supreme Court in 2022 when defendants challenged the outcome of hearings held online with witnesses or defendants not physically present.
The hearing formats were intended to reduce the risk of spreading COVID-19.
In those cases, the court ruled unanimously that there are no 'sick days' for constitutional rights.
'There's a fundamental right to be present for all critical stages,' Coyle said. 'The U.S. Supreme Court has said this, and the U.S. Supreme Court has also said that sentencing is a critical stage.'
Assistant Boone County prosecutor Yao Li, who argued that Buchanan should be pursuing his claims at the Missouri Supreme Court, also argued that the time for the challenge had long passed.
'The law of the case and lapse of jurisdiction prohibits him from raising the claim here,' Li wrote in his final brief to Harris.
Along with arguing that the 2003 resentencing was legal under state statute and rule,
Buchanan contends he was never legally sentenced and that has prevented him from seeking post-conviction relief.
Buchanan doesn't deny his guilt. He spoke at length about his case in an episode of the Netflix series 'I am a Killer.'
'We can never change the fact that my family members lost their lives, my girl, my friend, was shot,' Buchanan said in an April interview at Jefferson City Correctional Center. 'You can't put time on that.'
But he claims he has no memory of the crime. He said he believes marijuana he smoked that night was laced with PCP and tests of sweat residue in the shirt he wore shows that.
He cannot pursue those arguments without a final sentence, Buchanan said Wednesday in a telephone interview. That is why he needs an in-person sentencing.
'Any court in Missouri is obligated to honor my federal rights, because I'm dealing with a constitutional right,' Buchanan said. 'I have a constitutional right to be present.'
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