Miller v. Alabama
567 U. S. ____ (2012) (2012)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A sentencing scheme that mandates life in prison without the possibility of parole for offenders under the age of 18 at the time of their crimes violates the Eighth Amendment's prohibition on cruel and unusual punishments. Such a mandatory scheme is unconstitutional because it prevents the sentencer from considering the defendant's youth and its attendant characteristics as mitigating factors before imposing the harshest possible penalty for juveniles.
Facts:
- At age 14, Kuntrell Jackson and two other boys planned to rob a video store in Arkansas.
- Jackson learned one of the boys was carrying a sawed-off shotgun but proceeded with the plan, initially staying outside as a lookout.
- Jackson entered the store while his accomplice, Derrick Shields, was threatening the clerk, Laurie Troup.
- When Troup threatened to call the police, Shields shot and killed her, and the boys fled without taking any money. Jackson was not the shooter.
- In a separate case in Alabama, 14-year-old Evan Miller and a friend, Colby Smith, were smoking and drinking with a neighbor, Cole Cannon.
- After Cannon passed out, Miller stole his wallet. When Cannon awoke and grabbed Miller by the throat, Smith hit Cannon with a baseball bat.
- Miller then took the bat and repeatedly struck Cannon, placed a sheet over his head, and delivered a final blow.
- Miller and Smith set fire to Cannon's trailer to cover up the crime, and Cannon died from his injuries and smoke inhalation.
Procedural Posture:
- Kuntrell Jackson was charged as an adult in Arkansas state trial court for capital felony murder.
- A jury convicted Jackson, and the trial judge imposed the state's mandatory sentence of life without parole.
- The Arkansas Supreme Court affirmed the conviction.
- Jackson filed a state habeas corpus petition, which the state trial court dismissed. The Arkansas Supreme Court affirmed the dismissal.
- Evan Miller was transferred from juvenile to adult court in Alabama and charged with murder in the course of arson.
- A jury found Miller guilty, and he was sentenced to the state's mandatory punishment of life without parole.
- The Alabama Court of Criminal Appeals affirmed the sentence, and the Alabama Supreme Court denied review.
- The U.S. Supreme Court granted certiorari in both cases and consolidated them for review.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a state sentencing scheme that mandates life in prison without the possibility of parole for juvenile offenders convicted of homicide violate the Eighth Amendment's prohibition on cruel and unusual punishments?
Opinions:
Majority - Justice Kagan
Yes. A sentencing scheme that mandates life imprisonment without parole for juvenile homicide offenders violates the Eighth Amendment's prohibition on cruel and unusual punishments. Such mandatory schemes unconstitutionally prevent the sentencing authority from considering a juvenile's diminished culpability and greater capacity for change. By removing youth and its hallmark features from consideration, these laws contravene the foundational principles of Roper v. Simmons and Graham v. Florida, which establish that children are constitutionally different from adults for sentencing purposes. Furthermore, because life without parole is the ultimate penalty for a juvenile, it is analogous to the death penalty, which under precedents like Woodson v. North Carolina requires individualized sentencing that considers all mitigating factors, especially the defendant's youth.
Concurring - Justice Breyer
Yes. While agreeing with the majority, a juvenile who did not kill or intend to kill, like Kuntrell Jackson, has a 'twice diminished moral culpability' due to both youth and lack of homicidal intent. Therefore, the Eighth Amendment, as interpreted in Graham v. Florida, forbids a sentence of life without parole for such a juvenile, regardless of whether the sentencing scheme is mandatory or discretionary. The doctrine of 'transferred intent' from felony-murder is insufficient to establish the level of culpability required to impose this ultimate sentence on a juvenile who did not personally kill or intend to kill.
Dissenting - Chief Justice Roberts
No. Mandatory life without parole for juvenile murderers is not an 'unusual' punishment prohibited by the Eighth Amendment. The majority of states and the federal government authorize this sentence, and thousands of inmates are currently serving it, demonstrating there is no societal consensus against the practice. The Court's reliance on Roper and Graham is misplaced; those cases were explicitly limited to the death penalty and nonhomicide offenses, respectively. By invalidating the laws of dozens of legislatures, the Court is substituting its own subjective policy preferences for the democratic judgments of the people.
Dissenting - Justice Thomas
No. The Court's decision is not supported by the original understanding of the Cruel and Unusual Punishments Clause, which prohibits torturous methods of punishment, not sentences deemed disproportionate. The Court's precedents establishing categorical bans and requiring individualized sentencing in capital cases were wrongly decided and should not be extended. The decision in Harmelin v. Michigan correctly established that mandatory life sentences are permissible outside the death penalty context, and a defendant's age does not change that constitutional analysis.
Dissenting - Justice Alito
No. The Court has abandoned any connection to objective indicia of 'evolving standards of decency' and is now imposing its own subjective views. The decision prohibits legislatures from determining that certain categories of murderers under 18 must be imprisoned for life to protect society. This arrogates legislative authority and forces society to bear the risk that convicted murderers, if released, will kill again. The Court's jurisprudence is no longer tied to societal standards but is instead an inward-looking process of extrapolating from its own prior decisions.
Analysis:
This decision merges two distinct lines of Eighth Amendment jurisprudence: the categorical prohibitions on certain sentences for juveniles (Roper, Graham) and the requirement of individualized sentencing for the death penalty (Woodson, Lockett). By invalidating mandatory life-without-parole sentences for juvenile homicide offenders, the Court requires states to reform their sentencing laws to allow for judicial or jury discretion. The ruling establishes that youth and its attendant characteristics are constitutionally significant mitigating factors that must be considered, effectively making life without parole a less common sentence for juveniles, even in homicide cases. It solidifies the principle that 'children are different' for the purposes of imposing the state's harshest punishments.
