Montgomery v. Louisiana

Background

Henry Montgomery was 17 in 1963 when he killed a deputy sheriff in Louisiana. After a retrial a jury returned “guilty without capital punishment,” which under state law produced an automatic life-without-parole sentence, so Montgomery had no chance to present youth-related mitigation. Decades later this Court decided Miller v. Alabama, which said mandatory life without parole for juveniles violates the Eighth Amendment. Montgomery asked Louisiana courts to apply Miller to his long-final sentence, but the Louisiana Supreme Court said Miller was not retroactive on state collateral review.

Reasoning

The Court addressed whether Miller announces a substantive rule that must be applied retroactively in state postconviction proceedings. It held that substantive constitutional rules—those that remove a State’s power to impose a particular punishment on a class of defendants—must be applied retroactively. The Court concluded Miller did announce such a substantive rule because it made mandatory life without parole unconstitutional for all but the rare juvenile whose crime reflects irreparable corruption. The Court therefore reversed the Louisiana Supreme Court’s refusal to give Miller retroactive effect and sent the case back for further proceedings.

Real world impact

States that relied on automatic life-without-parole for juvenile homicide offenders must provide a remedy, for example by allowing parole eligibility or other review, rather than leaving the original mandatory sentence untouched. The decision does not automatically free every person who was sentenced long ago; it requires states and courts to provide the opportunity to show youth-related differences and possible rehabilitation.

Dissents or concurrances

Justice Scalia, joined by Justices Thomas and Alito, and Justice Thomas separately, dissented, arguing the Court lacked jurisdiction and that the ruling wrongly upends finality and state postconviction rules.