Miller v. Alabama
Headline: Court bars laws that force life without parole for people under 18 who commit murder, ruling mandatory life terms unconstitutional and requiring youth be considered at sentencing.
Holding: The Eighth Amendment forbids laws that mandate life imprisonment without the possibility of parole for people who were under 18 when they committed homicide because such schemes prevent sentencers from considering youth.
- Bars mandatory life-without-parole sentences for juvenile homicide offenders.
- Requires judges and juries to consider a child’s age and background at sentencing.
- Affects state laws that automatically impose life without parole on minors.
Summary
Background
Two 14-year-olds, described in the opinion as a boy who accompanied others to rob a video store and a boy who helped beat a neighbor and set a fire, were convicted of murder in adult court and automatically given life sentences without any possibility of parole. State laws in Arkansas and Alabama required that result once the boys were tried as adults; lower courts upheld those mandatory punishments and denied relief.
Reasoning
The Court held that the Eighth Amendment forbids sentencing schemes that mandate life in prison without parole for offenders who were under 18 when they committed homicide. Relying on earlier decisions that treat children as constitutionally different from adults (for example, decisions limiting the death penalty and banning life without parole for nonhomicide juvenile offenders), the majority explained that youth brings immaturity, greater susceptibility to influence, and more capacity for change. Mandatory terms remove the ability of judges or juries to consider those youth-related facts and any mitigating circumstances, producing a risk of disproportionate punishment.
Real world impact
The decision requires that sentencers be able to consider a juvenile’s age, background, role in the crime, and prospects for rehabilitation before imposing the harshest prison term. It does not categorically forbid life without parole in every juvenile homicide case, but it rejects statutes that make such a sentence automatic and sends the two cases back to the lower courts for further proceedings.
Dissents or concurrances
A concurring Justice emphasized that juveniles who did not kill or intend to kill present especially strong Eighth Amendment problems. Several dissenting Justices argued the Court overruled legislative judgments, pointed to widespread statutory use of mandatory sentences, and said judges should not displace those policy choices.
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