Miller v. Alabama
Headline: Mandatory life-without-parole for people under 18 is barred, forcing judges to consider a juvenile’s youth and circumstances before imposing lifetime prison sentences in homicide cases.
Holding: The Court held that mandatory life-without-parole sentences for offenders under 18 violate the Eighth Amendment because they forbid considering a juvenile’s youth and mitigating circumstances.
- Stops states from imposing automatic life-without-parole on anyone under 18.
- Requires judges to consider youth and background before imposing life sentences.
- Some juveniles may still receive life-without-parole after individualized sentencing in rare cases.
Summary
Background
Two 14-year-old offenders—Kuntrell Jackson in Arkansas and Evan Miller in Alabama—were convicted of murder and, under state law, automatically sentenced to life in prison without any possibility of parole. Both states’ laws left no sentencing discretion: the statutes required life without parole for the crimes at issue, and transfer procedures had sent each boy to adult court where the mandatory punishment applied.
Reasoning
The Court asked whether a law that mandates life without parole for anyone under 18 violates the Eighth Amendment’s ban on cruel and unusual punishment. Relying on its prior decisions about juvenile differences (Roper and Graham) and on cases requiring individualized sentencing for the most severe penalties, the Court explained that children have lesser blameworthiness and greater capacity for change. A mandatory life-without-parole term treats a child the same as an adult and prevents the sentencer from weighing youth, family background, role in the offense, and other mitigating factors. The Court therefore held that mandatory life-without-parole for offenders under 18 is unconstitutional, though it did not adopt a complete, categorical ban on all juvenile life-without-parole sentences.
Real world impact
States may not impose automatic life-without-parole for anyone under 18; sentencing authorities must be allowed to consider age-related features and other mitigating evidence before imposing the harshest sentence. The cases are returned for further proceedings consistent with this rule. The Court also said appropriate occasions for sentencing juveniles to life without parole will be uncommon, and it left open that individualized sentencing might still permit such a sentence in rare circumstances.
Dissents or concurrances
Justice Breyer (joined by Sotomayor) emphasized that if a juvenile neither killed nor intended to kill, life without parole is generally impermissible. The dissenters argued the majority overruless or displaces many legislative judgments and relied too little on how often States actually impose these sentences.
Opinions in this case:
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