Miller v. Alabama -- Mandatory Life Without Parole Sentences are Unconstitutional for Juveniles 

Posted June 26, 2012

On June 25, 2012, the United States Supreme Court, in Miller v. Alabama, ruled that imposing mandatory life sentences without the possibility of parole on juveniles violates the Eighth Amendment of the United States Constitution.  The Eighth Amendment “guarantees individuals the right not to be subjected to excessive sanctions”, and requires that punishments be proportionate to the crime committed. In this case the Court determined that proportionality must take into account “the mitigating qualities of youth.”  The Court’s rationale extended from previous cases, Roper v. Simmons and Graham v. Florida, detailing how juveniles are different from adults – prone to impulsive behavior and less able to understand the full impact of their actions – and why this makes them somewhat less culpable for their crimes, even when egregious. In the present cases, those who sentenced Evan Miller and Kuntrell Jackson had no discretion to impose different punishments because of mandatory minimum sentencing.  Under these sentencing structures, judges deciding Miller’s and Jackson’s sentences could not consider youth, or any other factors, that that may make the sentence disproportionate to the crime.  The court ruled that judges needed to examine all circumstances of a case and therefore, sentencing schemes that mandate life in prison without the possibility of parole for juvenile offenders violates the eighth amendment.

This ruling does not prevent states from imposing life sentences without the possibility of parole for homicide cases, only that a defendant’s age must be considered in making the sentencing determination.

Chief Justice John Roberts and justices Antonin Scalia, Clarence Thomas and Samuel Alito dissented in the 5-4 decision.  The Justices argued that decisions about appropriate sentences for juveniles is in the purview of state policy makers, and that their judgments should prevail over that of the Supreme Court.  All three dissenting opinions mentioned the court’s ruling showed a lack of deference to state policy.   

The brief for the state of Alabama notes that mandatory minimum sentences impacting juveniles exist in 26 states and with the Federal Government.

Resources:

Chart - 50 State Juvenile Life Without Parole