Christopher Peak pre-pandemic photo
Nitza Cruz (left), mother of Luis Noel Cruz, who recently won a reduced sentence.
For the second time in two years, a federal judge ruled that a former Latin King who was sentenced to life in prison for murders committed at 18 years old shouldn’t have to spend the rest of his days behind bars.
U.S. District Court Judge Janet Hall of New Haven issued that decision last Friday in the case United States of America v. Luis Noel Cruz.
The 31-page amended ruling comes roughly five weeks after Hall heard the latest petition by Cruz and his attorney for a reduction in the mandatory life sentence without parole that the now-45 year old received in 1996 for a double murder he committed in Bridgeport.
In her written decision, Hall agreed with the defendant’s claims that Cruz is eligible for compassionate release under the First Step Act due to a range of “extraordinary and compelling reasons” — including “his age at the time of his crimes, the length of his sentence, his extraordinary rehabilitation, the COVID-19 pandemic, and his family circumstances.”
Hall ordered that Cruz’s sentence be reduced to a term of 30 years, and that he be placed on special supervised release for five years to be followed by another five-year term on supervised release during which time he may not leave his home for any reason except a medical emergency or at the direction of the U.S. Probation Office.
Cruz was first sentenced to mandatory life in prison in 1996 after he was found guilty of shooting and killing one witness, Tyler White, the son of a New Haven police detective, in a car in Bridgeport in 1994. That same night, Cruz held down a perceived snitch, Arosmo “Ra-Ra” Diaz, as a fellow gang member shot and killed him.
Click here to read the decision in full.
Contributed photo
Judge Hall.
The federal judge’s most recent decision offers a similar outcome based on a similar line of reasoning in comparison to her February 2019 decision to drop Cruz’s life sentence to 35 years.
In both this most recent ruling and in the 2019 decision, Hall found that Cruz’s relative youth at the time of the double murder offered a compelling reason for why he should not have been judged as if he were a fully grown, emotionally mature adult.
In both instances, she cited scientific research on adolescent brain development for why Cruz’s mandatory life sentence handed down in 1996 should be reconsidered these two decades-plus later.
One of the key differences between the 2019 and 2021 decisions, however, lies in the legal grounding for Hall’s justification for reducing Cruz’s sentence.
In 2019, she found that the mandatory life sentence without parole that Cruz received for a crime committed when he was 18 violated was “cruel and unusual” and violated his Eighth Amendment rights.
That Constitutional argument was ultimately overturned by a federal appeals court in September 2020. In that decision, the higher court found that the Supreme Court has “chosen to draw the constitutional line at the age of 18 for mandatory minimum life sentences” — and therefore Cruz’s sentence did not violate the Eighth Amendment.
In her April 9 decision this year, Hall again turned to Cruz’s age at the time of the crime to justify her decision.
“It is uncontroversial that age, specifically youth, bears on an individual’s blameworthiness in committing a criminal offense,” Hall wrote. “Because of their reduced cognitive, interpersonal, and emotional capabilities, children and adolescents are less blameworthy than mature adults when they engage in criminal behavior.”
And, she wrote, the appeals court’s decision on the Constitutionality argument does not necessarily affect this current application under the First Step Act — nor does it affect the underlying scientific research.
“However, that the Supreme Court has drawn this line at age 18 for purposes of the Eighth Amendment does not extinguish the relevance of these characteristics in assessing, as a general matter, an 18-year-old’s blameworthiness in committing a crime,” Hall wrote.
“Certainly, it does not require that this court ignore, in the context of the instant section 3582(c) motion for a sentence reduction, what is plain: a person 20 weeks past his eighteenth birthday exhibits the same hallmark characteristics of youth that make those under 18 less blameworthy for criminal conduct than adults.”
Hall leaned on Cruz’s relative youth at the time of the crime — as well as on Cruz’s arguments that he faces a unique threat while locked up during Covid because he is overweight and suffers from hypertension, that he would be the primary care giver for his terminally ill mother if released early, and that he has demonstrated an extraordinary level of rehabilitation while behind bars — when explaining her final sentence reduction decision.
“The court finds the scientific evidence just discussed to be persuasive and well founded and concludes that, because 18-year-olds are still developing in terms of maturity, impulse control, ability to resist peer pressure, and character,” Hall wrote, “they are less than fully blameworthy for criminal conduct.”