Adams v. Alabama

Background

The case involves a man who killed and raped Melissa Mills in 1997 when he was 17. He was convicted, sentenced to death after a jury rejected youth as a reason for a lesser sentence, and later had his death sentence converted to life without parole after the Court outlawed juvenile death penalties. The Supreme Court granted review, vacated the lower court’s judgment, and sent the case back to the Alabama Court of Criminal Appeals for reconsideration in light of Montgomery v. Louisiana, which held that the Miller rule applies retroactively.

Reasoning

The core question is whether people sentenced to life without parole for crimes committed as minors received the individualized consideration Miller requires and whether their sentences remain lawful under Montgomery. The Court’s order grants review, vacates the judgment, and remands for the state courts to decide. Justices Thomas and Alito stressed that the remand does not decide whether the petitioner actually deserves relief or whether state procedural rules block relief. Justices Sotomayor and Ginsburg emphasized that Miller set a substantive rule: life without parole is only appropriate for the rare juvenile whose crimes show permanent incorrigibility, so lower courts must ask that exact question.

Real world impact

State courts must reexamine many long-closed juvenile sentences, especially those originally imposed as death sentences and later converted to life without parole. Many original proceedings were decades old and may not have asked the Miller question correctly. This order simply sends cases back for reconsideration; the final outcome for each person will depend on further state-court proceedings.

Dissents or concurrances

Concurring opinions differ on scope: some Justices warned the remand is not a merits ruling and noted potential procedural bars, while others urged careful substantive review under Miller and Montgomery.