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The Utah Supreme Court on Tuesday upheld the life-without-parole sentence of Robert Cameron Houston, who brutally raped and murdered a worker at a Clearfield home for troubled youths in 2006 when he was 17.
Four of the high court justices agreed that the punishment is constitutional — although he was a minor, the teen was tried as an adult — and rejected the argument that Houston received ineffective assistance from his defense attorneys.
The lone dissenter, Justice Christine Durham, wrote the sentence is unconstitutionally disproportionate for a juvenile and that Houston should have received the only other term available at the time of his 2007 sentencing, which was 20 years to life behind bars.
"Mr. Houston may well prove to be an irretrievably depraved individual, and a parole board may never deem him fit to rejoin society," Durham wrote. "Under this scenario, Mr. Houston would justifiably spend the rest of his days behind bars. I find it cruel and unusual, however, to make an irreversible determination that he should die in prison based upon even a heinous crime committed while he was a minor."
The court upheld Houston's punishment despite his troubled background. According to the ruling, Houston, who had an abusive father, tried to commit suicide at age 8 and was sexually abused for several months by his brother's friend when he was 12.
"This is an extremely uncommon case where the jury, considering the mitigating circumstances inherent to Mr. Houston's youth, nevertheless concluded that life without the possibility of parole was the appropriate sentence for the crime committed," Justice Ronald Nehring wrote for the majority.
In a deal with prosecutors, Houston pleaded guilty to aggravated murder in the slaying of 22-year-old Raechale Elton and charges of aggravated sexual assault and rape were dropped. After a sentencing hearing, a 2nd District jury voted 11-1 to sentence him to life imprisonment without the possibility of parole.
After he was sentenced, Houston got a new lawyer, who twice argued the case before the Utah Supreme Court, once before a U.S. Supreme Court ruling in an Alabama case banned mandatory life without parole sentences for juveniles and then again after the ruling.
Attorney John Pace argued that jurors didn't receive proper guidance on sentencing and might not have considered whether mitigating circumstances, such as the teen's mental health, could have outweighed aggravating factors.
But Assistant Utah Attorney General Christopher Ballard responded that the U.S. Supreme Court decision said only mandatory life-without-parole sentences are cruel and unusual punishment. He said the sentence fit the vicious crime and pointed out that Houston had been placed by the juvenile court at the home after two sexually motivated knife attacks, one on a teen relative and another on an adult aunt.
Elton gave Houston a ride Feb. 15, 2006, from a residential treatment center to his independent living home because it was snowing and she did not want the youth to have to walk the four blocks in bad weather, court documents say.
When they arrived at the home, Houston grabbed Elton, held a knife to her throat and raped her, according to the documents. When Elton would not stop screaming, the teen stabbed her in the side of the neck and slit her throat, then tried to break her neck and rip out her trachea, the documents say.
Houston got into Elton's car and sped off, driving into a house in what he claimed was an attempt to kill himself.
Ballard said Tuesday in a press release from the attorney general's office, "I am extremely relieved that the victim's family finally has a resolution in this case. The appellate process has been a long road and I am grateful that it has finally come to a favorable end." Ballard added: "The Court correctly affirmed the jury's conclusion that life without parole is the only appropriate sentence for this viciously selfish crime. This case did not involve just a single, inexplicable violent episode, but rather the culmination of a relentless history of escalating sexual violence."
Twitter: @PamelaMansonSLC