State v. Chaney - 477 P.2d 441 (Alaska 1970)

Rule:

Under Alaska's Constitution, the principles of reformation and necessity of protecting the public constitute the touchstones of penal administration. Multiple goals are encompassed within these broad constitutional standards. Within the ambit of this constitutional phraseology are found the objectives of rehabilitation of the offender into a noncriminal member of society, isolation of the offender from society to prevent criminal conduct during the period of confinement, deterrence of the offender himself after his release from confinement or other penological treatment, as well as deterrence of other members of the community who might possess tendencies toward criminal conduct similar to that of the offender, and community condemnation of the individual offender, or in other words, reaffirmation of societal norms for the purpose of maintaining respect for the norms themselves.

Facts:

Appellee Donald Scott Chaney was indicted on two counts of forcible rape and one count of robbery. After trial by jury, Chaney was found guilty on all three counts. The superior court imposed concurrent one-year terms of imprisonment and provided for parole in the discretion of the parole board. The State of Alaska has appealed from the judgment and commitment which was entered by the trial court. The State claimed that the one-year concurrent sentences were too lenient in view of the severity of the crimes of forcible rape and robbery. It argued that there was a need to deter others from such brutal behavior, and that the presentence recommendations called for significantly greater sentences than those imposed by the trial court.

Issue:

Was the sentence imposed too lenient?

Answer:

Yes.

Conclusion:

The court held that the sentence imposed was too lenient considering the circumstances surrounding the commission of the crimes. The trial court accorded little or no weight to several significant goals of the system of penal justice. Under Alaska's Constitution, the principles of reformation and necessity of protecting the public constitute the touchstones of penal administration. Multiple goals are encompassed within these broad constitutional standards. Within the ambit of this constitutional phraseology are the objectives of rehabilitation of the offender into a noncriminal member of society, isolation of the offender from society to prevent criminal conduct during the period of confinement, deterrence of the offender himself after his release from confinement or other penological treatment, as well as deterrence of other members of the community who might possess tendencies toward criminal conduct similar to that of the offender, and community condemnation of the individual offender, or in other words, reaffirmation of societal norms for the purpose of maintaining respect for the norms themselves.