Miller v. Alabama
|Miller v. Alabama|
|Argued March 20, 2012
Decided June 25, 2012
|Full case name||Evan Miller, Petitioner v. Alabama; Kuntrell Jackson, Petitioner v. Ray Hobbs, Director, Arkansas Department of Correction|
|Citations||567 U.S. ___ (more)|
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. ___ (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|
Miller v. Alabama, 567 U.S. ___ (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 extended beyond the Graham v. Florida (2010) case, which had ruled juvenile life without parole sentences unconstitutional for crimes excluding murder.
The decision of the court 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. He too was given a life term with no parole."
Opinion of the Court
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 added. “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. And he further 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 17 ½-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 to all those under 18, doesn't automatically free any prisoner, and it doesn't forbid life terms for young murderers. Instead judges have to consider the defendant’s youth 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.
- "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.
- 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).