State v. Chaney

Citation. 22 Ill. 477 P.2d 441 (Alaska 1970)

Brief Fact Summary. The Appellee, Donald Scott Chaney (Appellee), was convicted of two counts of forcible rape and one count of robbery. The trial court imposed a concurrent one-year sentence and provided for parole in the discretion of the parole board. Even though the law prohibits an increase in the sentence upon appeal, the State of Alaska filed this appeal in order to express its disapproval of the judgment of the trial court.

Synopsis of Rule of Law. The principles and objectives of criminal reformation are rehabilitation of the offender, isolation of the offender, deterrence of the offender, deterrence of other potentially similarly situated individuals in society and community condemnation of the offender in order to reaffirm societal norms.

Facts. The Appellee, a member of the United States Armed Forces and another individual picked up the victim at a downtown location in Anchorage. After driving around with the victim in their car, they beat her and forcibly raped her four times. Money was also removed from the victim’s purse. After the incident was over, the Appellee and his companion threatened the victim in order to make sure she did not tell anyone what had occurred. The Appellee claimed it was not forcible rape and that he did not direct any violence toward the victim. The Appellee also stated that he found some money on the floor of the car and was going to return it to the victim at a later time. The Appellee was convicted of two counts of forcible rape and one count of robbery. The trial court imposed a concurrent one-year sentence and provided for parole in the discretion of the parole board even though the presentencing recommendations were much more severe. Alaskan law prohibits an increase in the sentence u
pon appeal. However, the State of Alaska filed an appeal in order to express its disapproval with the judgment of the trial court. The state claims the sentences were too lenient in view of the severity of the crimes and in light of the need to deter others from such brutal behavior.

Issue. What goals should be achieved by the imposition of a sentence in a criminal case?

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Discussion. This case was written by Judge Rabinowitz of the Supreme Court of Alaska for the purpose of expressing the court’s disapproval of the sentence imposed by the trial court. The opinion outlines the state’s constitutional principles of reformation and the need for public protection against criminals. The court believes that a longer jail sentence would verify the seriousness of the Appellee’s conduct. It appears from the opinion, that the trial judge seemed apologetic with regard to his decision to impose a jail sentence. Even though the Appellee showed no remorse on the record about what had happened, his fine military service was discussed at length along with his possible eligibility for early parole. Not mentioned in sentencing was the victim of the Appellee’s crimes. The sentence imposed fell short of reaching the goal of reaffirmation of societal norms. This could lead to the conclusion that forcible rape and robbery are not demonstrative of serious antisocial conduct.

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