Montgomery v. Louisiana, 577 U.S. 190

Background

Henry Montgomery, aged 17 in 1963, was convicted of murder in Louisiana and, after retrial, received an automatic sentence of life without parole under state law because the jury returned "guilty without capital punishment."
Montgomery challenged his sentence after this Court decided Miller v. Alabama, arguing Miller made mandatory life-without-parole for juveniles unconstitutional and thus his sentence illegal.
Louisiana trial court denied relief, and the Louisiana Supreme Court (relying on its Tate decision) held Miller is not retroactive on state collateral review.
The Supreme Court granted certiorari to decide (1) whether it had jurisdiction to review the state court’s refusal to apply Miller retroactively and (2) whether Miller announced a substantive rule that must be applied retroactively on state collateral review.
The Court considered Teague’s framework for retroactivity on federal habeas review and whether Teague’s exception for substantive rules is a constitutional mandate binding state courts.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the Supreme Court have jurisdiction to review a state supreme court’s refusal to apply Miller retroactively on state collateral review?	Montgomery: Yes — refusal to apply a constitutional rule implicates federal law and is reviewable.	Louisiana/amicus: No — retroactivity for state collateral remedies is a matter of state law and not reviewable.	Yes — when a state court declines to apply a controlling substantive constitutional rule, federal courts have jurisdiction because the Supremacy Clause requires state courts to give effect to federal constitutional rules.
Is Teague’s rule limiting retroactivity on federal habeas review merely an interpretation of federal habeas statutes or a constitutional command binding state collateral review?	Montgomery: Teague’s exception for substantive rules rests on constitutional premises and binds states.	Amicus/Louisiana: Teague is statutory/interpretive of federal habeas law; states may adopt different retroactivity rules.	Teague’s protection for substantive rules is grounded in constitutional principles and therefore state collateral review courts must give retroactive effect to new substantive rules.
Did Miller v. Alabama announce a substantive rule (rather than purely procedural) such that it must be retroactive on collateral review?	Montgomery: Miller held life-without-parole is unconstitutional for the vast majority of juvenile offenders—a substantive categorical guarantee.	Louisiana: Miller is procedural because it requires sentencers to consider youth; it did not categorically bar the penalty.	Held Miller announced a substantive rule—it forbids a category of punishment for a class of defendants (most juveniles) and therefore is retroactive on collateral review.
What remedy may states provide to comply with Miller retroactively?	Montgomery: Relief may be parole eligibility or resentencing to cure the constitutional defect.	Louisiana: Concern about finality, burden, and practical difficulty of assessing decades-old facts like incorrigibility.	States may remedy Miller violations by making juvenile homicide offenders eligible for parole (or otherwise provide a meaningful opportunity to show they are not among the rare irreparably corrupt juveniles).

Key Cases Cited

Roper v. Simmons, 543 U.S. 551 (2005) (juvenile capital punishment prohibited; children are constitutionally different for sentencing)
Graham v. Florida, 560 U.S. 48 (2010) (Eighth Amendment bars life without parole for juvenile nonhomicide offenders)
Miller v. Alabama, 567 U.S. _ (2012) (mandatory life without parole for juvenile homicide offenders invalid without individualized consideration)
Teague v. Lane, 489 U.S. 288 (1989) (framework for retroactivity on federal habeas; substantive-rule exception)
Penry v. Lynaugh, 492 U.S. 302 (1989) (substantive-rule exception includes rules prohibiting certain punishments for classes of defendants)
Schriro v. Summerlin, 542 U.S. 348 (2004) (distinction between substantive and procedural rules; substantive rules not subject to Teague bar)
Danforth v. Minnesota, 552 U.S. 264 (2008) (States free to give broader retroactivity on state collateral review; did not decide constitutional status of Teague exceptions)
Ex parte Siebold, 100 U.S. 371 (1880) (convictions under unconstitutional statutes are void; historical support for retroactivity of substantive rules)
United States v. United States Coin & Currency, 401 U.S. 715 (1971) (strong rationale for complete retroactivity when conduct is constitutionally immune from punishment)