Aiken v. Byars
410 S.C. 534
S.C.2014Background
- Fifteen inmates sentenced to life without parole as juveniles petition for resentencing under Miller v. Alabama.
- The petitioners allege Miller’s prohibition on mandatory LWOP for juveniles applies to them and requires individualized consideration.
- SC held Miller retroactive under Teague, applying substantive rule to collateral review and to petitioners and similarly situated juveniles.
- The court concludes that any juvenile LWOP sentence (mandatory or discretionary) must be reviewed under Miller’s factors through an individualized hearing.
- The opinion directs resentencing within one year from the filing of the opinion, allowing evidence on youth characteristics to influence sentencing.
- Dissent argues Miller does not apply retroactively to discretionary LWOP schemes and would deny resentencing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Retroactivity of Miller | Petitioners | Respondents | Miller applies retroactively as a substantive rule |
| Applicability to nonmandatory LWOP | Petitioners | Respondents | Miller extends to juveniles sentenced under nonmandatory LWOP schemes |
| Scope of resentencing framework | Petitioners | Respondents | Resentencing must consider Miller factors; individualized youth analysis required |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory LWOP for juveniles unconstitutional; requires individualized consideration)
- Roper v. Simmons, 543 U.S. 551 (2005) (juveniles are different for capital punishment purposes)
- Graham v. Florida, 560 U.S. 48 (2010) (juvenile LWOP invalid for nonhomicide offenses)
- Teague v. Lane, 489 U.S. 288 (1989) (retroactivity framework for new constitutional rules)
- Woodson v. North Carolina, 428 U.S. 280 (1976) (requirement to consider the individual offender and circumstances)