Miller v. Alabama
132 S. Ct. 2455
SCOTUS2012Background
- Two 14-year-old offenders were convicted of murder and sentenced to life without parole with no discretionary relief under mandatory schemes.
- Arkansas and Alabama statutes mandated life without parole for juvenile homicide offenders, removing youth-based mitigation from sentencing.
- Courts previously held Roper and Graham limited harsh penalties for juveniles and required individualized consideration, especially for life-without-parole in juvenile cases.
- Jackson and Miller argued mandatory LWOP for juveniles violated the Eighth Amendment and Graham’s youth-mitigating framework.
- The Court reversed, holding that mandatory life without parole for juveniles is unconstitutional because it prevents consideration of age, maturity, and rehabilitation.
- The decision leaves room for discretionary LWOP in homicide cases but emphasizes that such sentences must involve individualized assessment of the youth.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does mandatory life without parole for juveniles violate the Eighth Amendment? | Jackson/Miller contended youth diminishes culpability; mandatory LWOP is disproportionate. | States argue Harmelin and precedent permit mandatory LWOP and rely on societal standards supporting such penalties. | Yes; mandatory LWOP for juveniles violates the Eighth Amendment. |
| Is Graham/Roper's individualized-sentencing principle applicable to juvenile homicide cases? | Youth factors must be considered; mandatory schemes ignore age-related mitigation. | Those precedents do not require a rule beyond capital contexts; transfer and age-based distinctions are separate issues. | Yes; these precedents require considering youth before imposing the harshest penalties. |
| Can discretionary transfer statutes justify mandatory LWOP for juvenile homicide offenders? | Transfer discretion could lead to LWOP despite youth, undermining proportionality. | Transfer discretion in some states preserves some individualized consideration. | No; discretionary transfer cannot substitute for post-trial individualized sentencing in the juvenile context. |
| Does the number of jurisdictions mandating LWOP for juveniles show national consensus against the punishment? | Widespread adoption indicates societal consensus against such sentences. | Legislative practice is not dispositive; Graham focuses on actual sentencing, not mere statutes. | No; consensus evidence does not justify upholding mandatory LWOP for juveniles. |
| If a juvenile did intend to kill or kill, is LWOP permissible? | Transferred intent or felony-murder principles could support LWOP in some scenarios. | Transferring intent is imperfect for Eighth Amendment purposes; Graham limits to cases where the juvenile killed or intended to kill. | Rule leaves room for individualized determination, but mandatory LWOP remains unconstitutional even where intent is debated. |
Key Cases Cited
- Graham v. Florida, 560 U.S. 48 (2010) (holds life without parole violates Eighth Amendment for juvenile nonhomicide offenders; importance of youth in punishment)
- Roper v. Simmons, 543 U.S. 551 (2005) (death penalty unconstitutional for under-18 offenders; youth differences emphasized)
- Kennedy v. Louisiana, 554 U.S. 407 (2008) (categorical limits on death penalty; focus on evolving standards and culpability)
- Atkins v. Virginia, 536 U.S. 304 (2002) (prohibits execution of mentally retarded; relevance to evolving standards and proportionality)
- Woodson v. North Carolina, 428 U.S. 280 (1976) (mandatory capital punishment unconstitutional due to lack of individualized considerations)
- Lockett v. Ohio, 438 U.S. 586 (1978) (mitigating factors must be considered in capital sentencing)
- Eddings v. Oklahoma, 455 U.S. 104 (1982) (youth background and development must be considered in culpability)
- Johnson v. Texas, 509 U.S. 350 (1993) (youthful circumstances as mitigating factors in sentencing)
- Enmund v. Florida, 458 U.S. 782 (1982) (limits on imputed intent for accomplices; transferred intent rejected for death penalty Eighth Amendment purposes)