Montgomery v. Louisana

Supreme Court of the United States
577 U. S. ____ (2016) (2016)

ELI5:

Rule of Law:

When a new rule of constitutional law is substantive, meaning it prohibits a certain category of punishment for a class of defendants, it must be applied retroactively on state collateral review. The Constitution requires state courts to give effect to such rules regardless of when a defendant's conviction became final.

Facts:

In 1963, Henry Montgomery, who was 17 years old at the time, killed a deputy sheriff named Charles Hurt in East Baton Rouge, Louisiana.
Montgomery was subsequently retried for murder.
The jury at his second trial returned a verdict of "guilty without capital punishment."
Under Louisiana law at the time, this verdict triggered a mandatory sentence of life in prison without the possibility of parole.
The trial court had no discretion to impose a lesser sentence and was not permitted to consider mitigating evidence, such as Montgomery's youth or his potential for rehabilitation.

Procedural Posture:

Henry Montgomery was first convicted of murder in a Louisiana trial court and sentenced to death.
The Louisiana Supreme Court, an appellate court, reversed that conviction.
Following a retrial, Montgomery was convicted again, and the trial court imposed a mandatory sentence of life without parole, which became a final judgment.
Years later, after the U.S. Supreme Court's decision in Miller v. Alabama, Montgomery filed a motion to correct an illegal sentence in the original Louisiana trial court.
The trial court denied his motion, holding that the rule from Miller was not retroactive.
The Louisiana Supreme Court, the state's highest court, denied Montgomery's application for review.
The U.S. Supreme Court granted a writ of certiorari to decide the issue of retroactivity.

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Issue:

Does the U.S. Supreme Court's decision in Miller v. Alabama, which prohibits mandatory life-without-parole sentences for juvenile homicide offenders, announce a new substantive rule that must be applied retroactively on state collateral review?

Opinions:

Majority - Justice Kennedy

Yes. Miller v. Alabama announced a new substantive rule that must be applied retroactively on state collateral review. First, the Court established that it has jurisdiction because the requirement for new substantive rules to apply retroactively is a constitutional command, not merely a feature of federal habeas law. Substantive rules, which forbid a certain punishment for a class of offenders, are distinct from procedural rules because they render a sentence void, and the Supremacy Clause requires state courts to remedy such a constitutional violation. Second, the Court held that Miller announced a substantive rule, not merely a procedural one. By determining that life without parole is a disproportionate and thus unconstitutional sentence for all but the rarest juvenile offenders whose crimes reflect "irreparable corruption," Miller placed that punishment beyond the state's power for a large class of defendants. The procedural component of Miller—a hearing to consider the juvenile's youth—is simply the mechanism required to give effect to this substantive constitutional guarantee. States can remedy a Miller violation by either resentencing the affected prisoners or by making them eligible for parole.

Dissenting - Justice Scalia

No. The Court's decision in Miller does not apply retroactively on state collateral review because the Court lacks jurisdiction and Miller announced a procedural rule. First, the Court has no jurisdiction because retroactivity on state collateral review is a matter of state law. The Teague v. Lane framework, which established exceptions for retroactivity, was an interpretation of the federal habeas statute and is not a constitutional command binding on state courts. Second, even if there were jurisdiction, Miller established a procedural rule, not a substantive one. The Miller opinion explicitly stated that it "does not categorically bar a penalty for a class of offenders" but instead "mandates only that a sentencer follow a certain process." The majority rewrites Miller to reach its desired outcome, creating an unworkable standard requiring courts to determine if a decades-old crime reflected "permanent incorrigibility." The majority's true aim is to effectively eliminate life without parole for juvenile offenders by making its imposition a practical impossibility and pressuring states to offer parole eligibility instead.

Dissenting - Justice Thomas

No. The Court's holding that there is a constitutional right to retroactive application of new substantive rules on collateral review has no basis in the Constitution's text or in American legal tradition. The Supremacy Clause is not an independent source of rights but simply provides a rule of decision if a federal right exists. No other provision, including Article III, the Due Process Clause, or the Equal Protection Clause, creates a right to collaterally attack a final judgment with a new rule. Historically, post-conviction relief has been a matter of legislative grace, not a constitutional mandate, and the principle of finality is a core component of the justice system. The Court's decision creates a new constitutional right without any textual or historical support, repudiating established principles of finality.

Analysis:

This decision significantly alters the landscape of collateral review by constitutionalizing Teague's exception for substantive rules, making it binding on state courts. Previously considered a feature of federal habeas law, this ruling forces states to provide a remedy for prisoners whose sentences are invalidated by new substantive constitutional rules, regardless of finality. The decision also substantively reinterprets Miller v. Alabama, classifying its holding as a categorical ban on life-without-parole for the vast majority of juvenile offenders, not just a procedural requirement for sentencing. This opens the door for thousands of inmates sentenced as juveniles to life without parole to seek release or parole eligibility, placing a significant burden on states to review decades-old cases.

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