CCBA Feature IN THE PENNSYLVANIA APPELLATE COURTS: COMMONWEALTH V. BATTS By Shannon K. McDonald, Esquire 16 | New Matter I n a legal decision that has made shockingly little press, the Pennsylvania Supreme Court has finally spoken on the issue of juvenile life without parole sentences (LWOP). Emphasis on finally, since this case has been to the Pennsylvania Supreme Court twice and since the United States Supreme Court stated unequivocally in 2012 (Miller v. Alabama) that life without parole should almost never be handed out to juvenile offenders, and that the vagaries of youth must be accounted for. Further, the United States Supreme Court spoke again in 2016, ordering that the decision must be applied retroactively, forcing Pennsylvania to reverse course and look to the hundreds of juveniles it had committed to life without parole sentences. Pennsylvania continues to resist this standard, up until this decision,