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. 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 24, 2012
|Full case name||Evan Miller, Petitioner v. Alabama; Kuntrell Jackson, Petitioner v. Ray Hobbs, Director, Arkansas Department of Correction|
|Citations||567 U.S. 460 (more)|
132 S. Ct. 2455; 183 L. Ed. 2d 407
|Prior||Conviction 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)|
|The Eighth Amendment prohibits a sentencing scheme that requires life in prison without the possibility of parole for juvenile homicide offenders.|
|Majority||Kagan, joined by Kennedy, Ginsburg, Breyer, Sotomayor|
|Concurrence||Breyer, joined by Sotomayor|
|Dissent||Roberts, joined by Scalia, Thomas, Alito|
|Dissent||Thomas, joined by Scalia|
|Dissent||Alito, joined by Scalia|
|U.S. Const. Amend. VIII|
The decision of the court was based on two consolidated cases, Jackson v. Hobbs, No. 10-9647, and Miller v. Alabama, No. 10-9646. 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 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. The other defendant was given a life term with no parole."
Jackson 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'." Jackson was not the shooter.
Evan 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 his (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.
Opinion of the CourtEdit
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". "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," Justice Kagan said. "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."
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." A separate dissent was filed by Justice Samuel Alito. "Even a 17½-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," Alito wrote of the consequences of the majority ruling. "Nothing in the Constitution supports this arrogation of legislative authority."
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.
The case was remanded to the trial court for the convicted youths to be re-sentenced.
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. 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. 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.
- "Miller v. Alabama". SCOTUSblog. Retrieved 28 June 2012.
- Savage, David G. (25 June 2012). "Supreme Court rules mandatory juvenile life without parole cruel and unusual". The Los Angeles Times. Retrieved 26 June 2012.
- Cohen, Andrew (26 June 2012). "If You Think Monday Was Bad at the Supreme Court ..." The Atlantic. Retrieved 26 June 2012.
- Adam Liptak and Ethan Bronner (25 June 2012). "Justices Bar Mandatory Life Terms for Juveniles". The New York Times. Retrieved 26 June 2012.
- Miller v. Alabama, 132 S. Ct. 2455, 567 U.S., 183 L. Ed. 2d 407 (2012).
- Barnes, Robert (25 June 2012). "Supreme Court says states may not impose mandatory life sentences on juvenile murderers". The Washington Post. Retrieved 26 June 2012.
- Miller v. Alabama, ___ U.S. ___, 132 S. Ct. 2455, 183 L. Ed. 2d 407 (2012).
- Denniston, Lyle (23 March 2015). "Court to try again on juveniles' life sentences". SCOTUSblog.
- "Petition for Writ of Certiorari" (PDF). SCOTUSblog. Retrieved 24 March 2015.
- Sherman, Mark (January 25, 2016). "Justices Extend Bar on Automatic Life Terms for Teenagers". ABC News. Associated Press.
- Stolberg, Sheryl Gay (26 May 2017). "Lee Boyd Malvo, Serving Life in 'Beltway Sniper' Case, Must Be Resentenced, Judge Says". The New York Times. Retrieved 27 May 2017.
- Associated Press (18 March 2019). "Supreme Court agrees to hear deadly D.C. sniper case". Politico. Retrieved 18 March 2019.