Miller v. Alabama

Miller v. Alabama, 567 U.S. 460 (2012), was a United States Supreme Court case in which the Court held that mandatory sentences of life without the possibility of parole are unconstitutional for juvenile offenders.[2][3] The ruling applied even to those persons who had committed murder as a juvenile, extending beyond Graham v. Florida (2010), which had ruled juvenile life without parole sentences unconstitutional for crimes excluding murder.

Miller v. Alabama
Argued March 19, 2012
Decided June 25, 2012
Full case nameEvan Miller, Petitioner v. Alabama; Kuntrell Jackson, Petitioner v. Ray Hobbs, Director, Arkansas Department of Correction
Docket nos.10-9646
10-9647
Citations567 U.S. 460 (more)
132 S. Ct. 2455; 183 L. Ed. 2d 407
Case history
PriorConviction affirmed sub nom. Miller v. State, 2010 WL 2546422 (Ala. Crim. App. June 25, 2010); rehearing denied, and new decision published, 63 So.3d 676 (Ala. Crim. App. August 27, 2010); certiorari denied sub nom. Ex parte Miller, unpub. n°1091663 (Ala. October 22, 2010); certiorari granted, 565 U. S. 1013 (2011). Conviction affirmed sub nom. Jackson v. State, 359 Ark. 87, 194 S.W.3d 757 (2004); petition for habeas relief dismissed, unpub. n°cv-08-28-2 (Jefferson Cnty Cir. Ct.); affirmed, 2011 Ark. 49, 378 S. W. 3d 103 (2011); certiorari granted, 565 U. S. 1013 (2011)
Holding
The Eighth Amendment prohibits a sentencing scheme that requires life in prison without the possibility of parole for juvenile homicide offenders.[1]
Court membership
Chief Justice
John Roberts
Associate Justices
Antonin Scalia · Anthony Kennedy
Clarence Thomas · Ruth Bader Ginsburg
Stephen Breyer · Samuel Alito
Sonia Sotomayor · Elena Kagan
Case opinions
MajorityKagan, joined by Kennedy, Ginsburg, Breyer, Sotomayor
ConcurrenceBreyer, joined by Sotomayor
DissentRoberts, joined by Scalia, Thomas, Alito
DissentThomas, joined by Scalia
DissentAlito, joined by Scalia
Laws applied
U.S. Const. Amend. VIII

Background

The decision of the court was based on two consolidated cases, Jackson v. Hobbs, No. 10-9647, and Miller v. Alabama, No. 10-9646.[4] The Los Angeles Times wrote: "In one case that came before the court, Kuntrell Jackson was 14 when he and two other teenagers went to a video store in Arkansas planning to rob it. He stayed outside, and one of the youths pulled a gun and killed the store clerk. Jackson had waited outside the store for a time, but entered shortly before Derrick Shields shot the store clerk. There is debate as to whether he told the clerk, "We ain't playin'" or whether he said to his accomplices, "I thought you all was playin'."[5] Jackson was not the shooter. Jackson was charged as an adult and given a life term with no parole.

In the second case, Evan Miller, a 14-year-old from Alabama, was convicted of murder after he and another boy set fire to a trailer where they had bought drugs from a neighbor. Miller committed homicide in the act of robbing his neighbor, Cole Cannon. Cannon had fallen asleep after he, Miller, and Miller's friend Colby Smith had indulged in alcohol and marijuana. Cannon awoke as Miller was replacing Cannon's wallet, and Smith hit Cannon with a baseball bat. Miller took up the bat and proceeded to severely beat Cannon. Smith and Miller later returned to destroy the evidence of what they had done by setting fire to Cannon's trailer. Cannon died of severe injuries and smoke inhalation.[5] Miller was given a life term with no parole. While Smith received life with parole."[2]

Opinion of the Court

Majority opinion

Justice Elena Kagan wrote for the majority of the court "that mandatory life without parole for those under age of 18 at the time of their crime violates the 8th Amendment’s prohibition on cruel and unusual punishments".[2] Justice Kagan said:

Mandatory life without parole for a juvenile precludes consideration of his chronological age and its hallmark features – among them, immaturity, impetuosity, and failure to appreciate risks and consequences. It prevents taking into account the family and home environment that surrounds him – and from which he cannot usually extricate himself – no matter how brutal or dysfunctional.[4]

Dissents

Chief Justice John Roberts voiced in his dissent the opinion that mandatory life sentences "could not plausibly be described" as unusual when a majority of states endorse them. He wrote: "Determining the appropriate sentence for a teenager convicted of murder presents grave and challenging questions of morality and social policy. Our role, however, is to apply the law, not to answer such questions."[6] A separate dissent was filed by Justice Samuel Alito. Alito wrote of the consequences of the majority ruling:

Even a ​17 1⁄2-year-old who sets off a bomb in a crowded mall or guns down a dozen students and teachers is a 'child' and must be given a chance to persuade a judge to permit his release into society. Nothing in the Constitution supports this arrogation of legislative authority.[4]

The holding of the court applies retroactively to all those convicted of crimes committed under 18. It does not automatically free any prisoner, and it does not forbid sentences of life terms for young murderers. Instead judges in their review have to consider the defendant's youth, mitigating factors, and the nature of the crime before sentencing the defendant to imprisonment with no hope for parole.[2]

The case was remanded to the trial court for the convicted youths to be re-sentenced.[7]

Retroactivity

In Montgomery v. Louisiana (2016), the Supreme Court determined that Miller v. Alabama must be applied retroactively. The petitioner, Henry Montgomery, has been in prison since 1963 for a murder he committed at the age of 17.[8][9][10] The Court said that states could undertake re-sentencing, or offer parole to inmates sentenced to life as minors. Up to 2,300 cases nationwide may be affected by the ruling.

Another case affected by the ruling would be the sentence that Lee Boyd Malvo received for his role in the D.C. sniper attacks, with a judge making a ruling similar to Montgomery v. Louisiana.[11] Malvo's trial progress had earlier been affected by Roper v. Simmons, which took the death penalty out of play for Malvo, who had been charged with capital murder. On March 18, 2019, the Supreme Court agreed to hear oral arguments for Mathena v. Malvo.[12][13]

Kuntrell Jackson was released from prison on February 21, 2017.[14]

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References
  1. "Miller v. Alabama". SCOTUSblog. Retrieved June 28, 2012.
  2. Savage, David G. (June 25, 2012). "Supreme Court rules mandatory juvenile life without parole cruel and unusual". The Los Angeles Times. Retrieved June 26, 2012.
  3. Cohen, Andrew (June 26, 2012). "If You Think Monday Was Bad at the Supreme Court ..." The Atlantic. Retrieved June 26, 2012.
  4. Adam Liptak and Ethan Bronner (June 25, 2012). "Justices Bar Mandatory Life Terms for Juveniles". The New York Times. Retrieved June 26, 2012.
  5. Miller v. Alabama, 132 S. Ct. 2455, 567 U.S., 183 L. Ed. 2d 407 (2012).
  6. Barnes, Robert (June 25, 2012). "Supreme Court says states may not impose mandatory life sentences on juvenile murderers". The Washington Post. Retrieved June 26, 2012.
  7. Miller v. Alabama, ___ U.S. ___, 132 S. Ct. 2455, 183 L. Ed. 2d 407 (2012).
  8. Denniston, Lyle (March 23, 2015). "Court to try again on juveniles' life sentences". SCOTUSblog.
  9. "Petition for Writ of Certiorari" (PDF). SCOTUSblog. Retrieved March 24, 2015.
  10. Sherman, Mark (January 25, 2016). "Justices Extend Bar on Automatic Life Terms for Teenagers". ABC News. Associated Press.
  11. Stolberg, Sheryl Gay (May 26, 2017). "Lee Boyd Malvo, Serving Life in 'Beltway Sniper' Case, Must Be Resentenced, Judge Says". The New York Times. Retrieved May 27, 2017.
  12. Associated Press (March 18, 2019). "Supreme Court agrees to hear deadly D.C. sniper case". Politico. Retrieved March 18, 2019.
  13. Smith, Matt (March 15, 2017). "Evan Miller Offers Apology As Resentencing Hearing Wraps". Juvenile Justice Information Exchange. Retrieved August 12, 2020.
  14. "Sutton's Conversation with Kuntrell Jackson, Plaintiff in the U.S. Supreme Court Case Jackson v. Hobbs". ACLU Missouri. August 15, 2019. Retrieved August 12, 2020.
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