Also known as:term of his natural life · term of her natural life · life imprisonment · natural life sentence
Written by attorneys · grounded in primary & secondary sources — see below
A person's physical life span. The phrase measures the duration of an interest or sentence by reference to the actual period the individual remains alive.
Sources & Authorities· 9 primary sources
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Cases
Statutes
Federal Rules
Model Codes
How it applies
Common Examples
6
Juvenile Non-Homicide Sentence
Nolan Nunez, age seventeen, set a fire that caused extensive property damage but no deaths. The court sentenced him to life imprisonment without parole. Because he was a juvenile and the offense was non-homicide, the sentence for the rest of his natural life is unconstitutional.
Recidivist Bad-Check Sentence
Nancy Nelson passed a bad check after prior nonviolent felonies. The court imposed life imprisonment without parole. The sentence extending to the end of her natural life is disproportionate under the Eighth Amendment.
Solem v. Helm463 U.S. 277, 279, 103 S.Ct. 3001, 77 L.Ed.2d 637 (1983)
Murder Presumption Challenge
Noah Nakamura was charged with murder after a fatal shooting. The prosecution relied on a presumption that malice could be inferred from the act alone. The court required the state to prove every element beyond a reasonable doubt before imposing a sentence for the remainder of his natural life.
Mullaney v. Wilbur421 U.S. 684, 95 S.Ct. 1881, 44 L.Ed.2d 508 (1975)
Sentence Enhancement Facts
Nora Nash was convicted of a weapons offense. The judge found a hate-crime motive by a preponderance of the evidence and added years that effectively produced a life term. The enhancement facts must be submitted to the jury before any sentence measured by the defendant's natural life can be imposed.
Apprendi v. New Jersey530 U.S. 466 (2000)
Insanity Defense Evidence
Naveen Nanda raised an insanity defense in a capital murder trial. The state restricted expert testimony on his mental condition. The limitation affected whether the jury could impose a sentence lasting the rest of his natural life.
Clark v. Arizona548 U.S. 735, 752 n.20, 126 S.Ct. 2709, 165 L.Ed.2d 842 (2006)
Mens Rea Requirement
Noelle North was prosecuted for converting government property. The court instructed the jury that intent to steal must be shown. Without that proof the government could not obtain a conviction carrying a sentence for the balance of her natural life.
Morrissette v. United States342 U.S. 246, 72 S.Ct. 240, 96 L.Ed. 288.
Common questions
Frequently Asked
4
What does a sentence for the rest of one's natural life mean?+
It means imprisonment for the defendant's entire remaining physical life span, typically without parole eligibility.
Can a juvenile receive a natural-life sentence for a non-homicide offense?+
No. The Eighth Amendment categorically prohibits life imprisonment without parole for juveniles convicted of non-homicide crimes.
How does the phrase appear in life-estate language?+
Courts treat 'during her natural life' as language of limitation that creates an estate measured by the life tenant's physical lifespan.
Does a life-without-parole sentence always extend to natural life?+
Yes. A sentence of life imprisonment without the possibility of parole continues until the defendant's death.
466 U.S. 668 (1984)Criminal Procedure
…of death is qualitatively different from a sentence of imprisonment, however long. Death, in its finality, differs more from life imprisonment than a 100-year prison term differs from one of only a year or two. Because of that qualitative difference, there is a corresponding difference in the need for reliability in the…