Miller v. Alabama
The Supreme Court ruled that states cannot automatically sentence a teenager convicted of murder to life in prison without parole. Judges and juries must first be allowed to weigh the teenager's youth and personal circumstances before handing down that sentence.
The decision does not ban life-without-parole for juvenile killers outright, but it means the harshest possible prison sentence can no longer be a foregone conclusion once a teenager is convicted of murder.
“We therefore hold that mandatory life without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment’s prohibition on “cruel and unusual punishments.””
The Court's core holding banning mandatory juvenile life-without-parole sentences.
How it got here: Both defendants received mandatory life-without-parole sentences; Arkansas's and Alabama's top courts upheld the sentences, and the Supreme Court agreed to review both cases together.
The Case in Depth
What happened
Kuntrell Jackson, 14, was convicted of murder after a robbery in which a companion shot and killed a store clerk; Jackson himself did not fire the gun. Evan Miller, also 14, beat a neighbor with a baseball bat and helped set fire to his trailer, killing him. Both were tried as adults and, under state law, automatically received mandatory sentences of life in prison without any possibility of parole.
The question before the Court
Can a state force a judge to send a 14-year-old convicted of murder to prison for life with no chance of parole, no matter what?
Why it matters
Roughly 2,000 people who received mandatory life-without-parole sentences as teenage murderers could now seek new, individualized sentencing hearings. Going forward, judges and juries in the states that used mandatory sentencing schemes must consider a young defendant's age, family background, and role in the crime before imposing this life sentence.
What changes now
The cases go back to the Arkansas and Alabama courts for new sentencing proceedings in which a judge or jury must consider the defendants' youth and circumstances before deciding whether life without parole is appropriate. The ruling opened the door for many of the roughly 2,000 people nationwide serving mandatory juvenile life-without-parole sentences to seek resentencing, though the Court left it open how broadly this decision would apply to already-final sentences.
What this does not decide
The Court did not ban life-without-parole sentences for juvenile murderers outright — it only barred making such a sentence automatic. Judges may still choose to impose life without parole after considering a juvenile's age and circumstances, though the Court said it expects such sentences to be rare.
Concurrences and dissents
Concurrence — Justice Breyer
Justice Breyer, joined by Justice Sotomayor, argued that under Graham's logic, a juvenile who did not kill or intend to kill the victim cannot constitutionally receive life without parole at all, regardless of whether the sentence is mandatory or discretionary. He would require a specific finding on remand of whether Jackson killed or intended to kill before any life-without-parole sentence could be reimposed, and argued that felony-murder-style 'transferred intent' cannot substitute for that finding.
Dissent — Justice Roberts
“Put simply, if a 17-year-old is convicted of deliberately murdering an innocent victim, it is not “unusual” for the murderer to receive a mandatory sentence of life without parole.”The dissent's central objection that the sentence cannot be called constitutionally 'unusual.'
Chief Justice Roberts argued that a punishment imposed by dozens of legislatures and applied to thousands of offenders cannot be called 'unusual,' so the majority's holding has no grounding in the Eighth Amendment's actual text. He contended that Roper and Graham deliberately confined their reasoning to the death penalty and nonhomicide crimes, and that the majority's decision opens the door to further erosion of legislatures' power to set criminal sentences.
Dissent — Justice Thomas
Justice Thomas argued that the Eighth Amendment, properly understood, only bars torturous methods of punishment and contains no general proportionality principle, so neither the categorical-ban cases nor the individualized-capital-sentencing cases the majority relies on were rightly decided in the first place. He would have upheld the states' sentencing schemes entirely, faulting the majority for building an illegitimate new rule on an already-flawed foundation.
Dissent — Justice Alito
Justice Alito warned that the ruling strips states of the power to guarantee that even the most brutal teenage killers, including 17½-year-olds who commit mass violence, can be permanently incarcerated. He argued the Court's Eighth Amendment cases have become untethered from any objective evidence of society's standards and are now driven purely by the Justices' own evolving moral views.
How the Court got there
The legal reasoning, step by step
- The Court combined two lines of Eighth Amendment cases: decisions barring certain punishments entirely for whole categories of offenders (like banning the death penalty for juveniles), and decisions requiring individualized sentencing before imposing the death penalty.
- Drawing on Roper v. Simmons and Graham v. Florida, the Court reasoned that children are 'constitutionally different' from adults for sentencing purposes because of their immaturity, vulnerability to outside pressures, and greater capacity to change as they grow older.
- The Court found that mandatory sentencing schemes assume a juvenile is exactly like an adult offender, since they give the judge or jury no chance to consider the offender's age, family situation, or level of involvement in the crime before handing down the harshest possible prison term.
- Because life without parole shares key features with the death penalty — it is irrevocable and forecloses any possibility of release — the Court applied its death-penalty rule requiring individualized consideration of mitigating circumstances to this sentence as well.
- The Court rejected the states' argument that the number of jurisdictions imposing mandatory life-without-parole sentences showed a national consensus in favor of the practice, noting many of those laws resulted from combining unrelated adult-transfer and general sentencing statutes rather than deliberate legislative choices.
- The Court concluded that a sentencing scheme removing the judge's or jury's ability to weigh youth before imposing this harshest possible prison term creates too great a risk of disproportionate punishment and therefore violates the ban on cruel and unusual punishment.
Doctrinal impact
Cases affected by this decision
Reaffirms Graham v. Florida (560 U. S. ___)
The Court builds directly on Graham's reasoning that youth matters and extends it from nonhomicide crimes to homicide sentencing.
Distinguishes Harmelin v. Michigan (501 U. S. 957)
The Court says Harmelin's refusal to require individualized sentencing for adults does not apply to juvenile offenders.
Reaffirms Roper v. Simmons (543 U. S. 551)
The Court relies on Roper's reasoning that children are less culpable than adults for sentencing purposes.