State v. Gonzalez

Held that the defendant’s mental health, which included diagnoses of depression, adjustment disorder, anxiety, opioid use disorder, and posttraumatic stress disorder, could not be considered in determining whether minimum mandatory sentence of 90 months in prison was unconstitutionally disproportionate to the crime of first-degree arson. Unlike intellectual disability, there were no indications, statutory or otherwise, of a consensus that persons with defendant’s mental health attributes were less culpable than those without them. Also held that a mandatory minimum sentence of 90 months in prison for first-degree arson was not so disproportionate to the defendant’s conduct so as to shock moral conscience of reasonable persons, and, thus, the sentence did not violate the state constitutional provision requiring that all penalties be proportioned to the offense. Although defendant had multiple mental health diagnoses, she had the requisite mental state and possessed the ability to appreciate the criminality of her actions.