Montgomery v. Louisiana

Background

Henry Montgomery was 17 in 1963 when he killed a deputy sheriff in Louisiana. A jury later found him “guilty without capital punishment,” which under Louisiana law automatically produced a life-without-parole sentence. Montgomery had no opportunity at his sentencing to present evidence about his youth or capacity to change. After this Court decided Miller v. Alabama (2012), which limited mandatory life-without-parole for juveniles, Montgomery asked state courts to apply Miller to his decades-old sentence; the Louisiana Supreme Court refused.

Reasoning

The central question was whether Miller announced a substantive constitutional rule that must be applied retroactively in state postconviction review. The Court explained that substantive rules forbid the State from imposing certain punishments on a class of people and therefore must be given retroactive effect, unlike purely procedural changes. Miller concluded that mandatory life without parole for juvenile homicide offenders is disproportionate for most children because youth lessens blame and increases prospects for reform. That made Miller a substantive rule, and the Court held states must apply it in their own collateral-review proceedings.

Real world impact

People who were sentenced as juveniles to mandatory life without parole can seek relief in state postconviction courts. States may remedy Miller violations by offering parole consideration or other measures consistent with Miller rather than automatically releasing every prisoner. The decision reverses Louisiana’s refusal and sends Montgomery’s case back for further proceedings.

Dissents or concurrances

A dissent argued the Court lacked jurisdiction to impose this rule on state collateral review and disagreed that Miller was a retroactive substantive rule; those Justices would leave retroactivity rules to the States.