Miller v. Alabama
The Supreme Court ruled that states cannot automatically sentence a child convicted of murder to life in prison with no possibility of parole. Judges and juries must first be allowed to consider the young defendant's age and background before imposing that punishment.
The decision does not ban life-without-parole for juveniles outright, but it means the harshest possible prison sentence can no longer be handed down as a one-size-fits-all rule for anyone under 18 convicted of homicide.
How it got here: State courts in Alabama and Arkansas upheld both mandatory life-without-parole sentences on appeal, and the Supreme Court agreed to review both cases together.
The Case in Depth
What happened
Two 14-year-olds, Kuntrell Jackson in Arkansas and Evan Miller in Alabama, were each convicted of murder as adults. Jackson took part in a robbery during which an accomplice shot and killed a store clerk; he did not fire the gun. Miller and a friend beat and killed a neighbor and set fire to his trailer after a night of drinking. Both received sentences of life without parole because their state's law required that punishment automatically for their crimes.
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 the circumstances?
The Court's answer
No — the Court ruled that states cannot mandate life without parole for a juvenile convicted of murder. A sentencing judge or jury must first have the chance to consider the offender's youth, family background, and role in the crime before imposing that punishment. The ruling built on earlier cases finding that children are less culpable than adults and more capable of change, and it borrowed from death-penalty cases requiring individualized consideration before imposing the harshest possible punishment.
The decision does not abolish life without parole for juveniles altogether — states may still impose it, but only case by case, after weighing a young defendant's particular circumstances, and the Court suggested such sentences should be uncommon.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Roughly 2,000 people who were sentenced to mandatory life without parole as juveniles could eventually seek new sentencing hearings. Going forward, the 29 states and the federal government that had mandatory schemes for juvenile homicide offenders must change their laws to let judges or juries weigh a young defendant's age, family situation, and role in the crime before imposing the harshest possible sentence.
What changes now
The Court sent both cases back to the Arkansas Supreme Court and the Alabama Court of Criminal Appeals for new proceedings consistent with the ruling, meaning Jackson and Miller must receive new sentencing consideration that accounts for their age and circumstances. Because the ruling struck down mandatory schemes in dozens of jurisdictions, other juvenile offenders sentenced under similar mandatory laws may also be entitled to new sentencing hearings. States remain free to still impose life without parole on juveniles, but only after an individualized hearing.
What this does not decide
The Court expressly declined to decide whether the Eighth Amendment requires a complete, categorical ban on life without parole for all juveniles or those 14 and younger. It held only that such a sentence cannot be mandatory; judges and juries may still choose to impose it after considering the juvenile's age and circumstances.
Concurrences and dissents
Concurrence — Justice Breyer
Justice Breyer, joined by Justice Sotomayor, agreed with the majority but added that under Graham's reasoning, a juvenile who did not personally kill or intend to kill cannot receive life without parole at all, regardless of whether the sentence is mandatory or discretionary. He argued this bars using a felony-murder theory of 'transferred intent' to justify the sentence, and that Jackson's case likely falls into this category since he did not shoot the clerk and may not have intended her death.
Dissent — Justice Roberts
Chief Justice Roberts, joined by Scalia, Thomas, and Alito, argued that a punishment imposed by most legislatures and applied to nearly 2,500 prisoners cannot fairly be called 'unusual,' which the Eighth Amendment actually requires. He argued the majority stretched Roper and Graham beyond their own express limits and that the decision usurps legislatures' authority to set sentencing policy for serious crimes.
Dissent — Justice Thomas
Justice Thomas, joined by Scalia, argued that the Eighth Amendment's original meaning only bars torturous methods of punishment, not disproportionate sentences, so the entire line of categorical-proportionality and individualized-capital-sentencing cases the majority relies on was wrongly decided from the start. He would have upheld the sentences because the Constitution leaves such judgments to legislatures.
Dissent — Justice Alito
Justice Alito, joined by Scalia, warned that the ruling strips legislatures of the power to guarantee that anyone who commits certain murders as a minor, even a 17-and-a-half-year-old who commits a mass killing, will never be released. He argued the Court's Eighth Amendment cases have become detached from any objective evidence of societal standards and are now driven purely by the Justices' own evolving views.
How the Court got there
The legal reasoning, step by step
- The Court combined two lines of precedent: cases categorically barring certain punishments for classes of offenders based on their reduced culpability, and cases requiring individualized sentencing before imposing the death penalty, which considers the specific defendant and crime rather than a one-size-fits-all rule.
- Drawing on Roper v. Simmons (barring the death penalty for juveniles) and Graham v. Florida (barring life without parole for juveniles who did not commit homicide), the Court reasoned that children are 'constitutionally different' from adults for sentencing because of their immaturity, vulnerability to outside pressure, and capacity for change.
- Because Graham had also compared life-without-parole sentences to the death penalty, the Court concluded that the same individualized-sentencing principle used in capital cases -- letting the sentencer weigh a defendant's youth and circumstances -- should extend to juveniles facing this harshest non-capital penalty.
- The Court rejected the states' argument that Harmelin v. Michigan barred this result, explaining that Harmelin dealt with adult offenders and never addressed children, so it did not control here.
- The Court also rejected the argument that because 29 jurisdictions authorized mandatory life without parole for some juveniles, the punishment could not be called unusual, reasoning that many of those laws arose only from the interaction of separate transfer and sentencing statutes rather than deliberate legislative choices about juveniles specifically.
- Applying these principles, the Court concluded that any sentencing scheme removing a judge's or jury's ability to consider a juvenile's age and circumstances before imposing life without parole violates the Eighth Amendment's ban on cruel and unusual punishment.
Doctrinal impact
Cases affected by this decision
Distinguishes Harmelin v. Michigan (501 U. S. 957)
The Court said its ruling does not conflict with Harmelin because that case never addressed juvenile offenders.
Reaffirms Graham v. Florida
The Court extended Graham's reasoning about children's diminished culpability from nonhomicide cases to homicide cases.
Reaffirms Roper v. Simmons (543 U. S. 551)
The Court relied on Roper's finding that children are less culpable than adults to support today's rule.
Reaffirms Woodson v. North Carolina (428 U. S. 280)
The Court relied on Woodson's rule against mandatory death sentences to require individualized juvenile sentencing.