June 25, 2012

Supreme Court Decides Miller v. Alabama and Jackson v. Hobbs

On June 25, 2012, the U.S. Supreme Court decided Miller v. Alabama, No. 10-9646, and Jackson v. Hobbs, No. 10-9647, holding that a state's mandatory minimum sentence of life without parole for juvenile offenders violates the Eight Amendment's proscription on "cruel and unusual punishment." Instead, individualized sentencing determinations must be made, taking into account the offender's youth.

The state of Arkansas charged Kuntrell Jackson as an adult with capital felony murder and aggravated robbery for his role in the robbery of a video store that resulted in the death of the store clerk. Jackson was fourteen years old at the time of the offense. The state of Alabama charged Evan Miller as an adult with murder in the course of arson for his role in the death of a man whom he had attempted to rob. Miller was also fourteen years old at the time of his offense. Jackson and Miller were convicted and sentenced under their states' respective sentencing schemes to mandatory minimum sentences of life without parole. Jackson and Miller challenged their sentences as "cruel and unusual punishment" under the Eighth Amendment. Both states' supreme courts left the sentences intact. 

The Supreme Court reversed, holding that the mandatory sentencing schemes violated the Eighth Amendment. The Court determined that the "confluence" of two lines of precedent led to this conclusion. The first line of precedent focused on "mismatches between the culpability of a class of offenders and the severity of a penalty." The second line of precedent required that, instead of imposing mandatory sentences of capital punishment, "sentencing authorities [must] consider the characteristics of a defendant and the details of his offense before sentencing him to death." Within these lines of cases, Roper v. Simmons had invalidated the death penalty for juveniles and Graham v. Florida had announced a "flat ban on life without parole … [for] nonhomicide crimes committed by juveniles."

The Court found that the reasoning in Roper and Graham regarding children's "distinctive (and transitory) mental traits and environmental vulnerabilities" was not "crime-specific." Thus, the Court applied the reasoning of Roper, Graham, and other cases from the two lines of precedent and concluded that "[m]andatory life without parole for a juvenile precludes consideration of his chronological age and its hallmark features—among them, immaturity, impetuosity, and failure to appreciate risks and consequences." The Court also noted that such a sentence prevents the sentencer from taking into account an offender's "family and home environment" and "the circumstances of the homicide offense," and "disregards the possibility of rehabilitation even when the circumstances most suggest it."  The Court did not impose a "categorical bar" on sentences of life without parole for juveniles, but the sentencer must "take into account how children are different, and how those differences counsel against irrevocably sentencing them to a lifetime in prison."

Justice Kagan delivered the opinion of the Court, in which Justices Kennedy, Ginsburg, Breyer, and Sotomayor joined. Justice Breyer filed a concurring opinion, in which Justice Sotomayor joined. Chief Justice Roberts filed a dissenting opinion, in which Justices Scalia, Thomas, and Alito joined. Justice Thomas filed a dissenting opinion, in which Justice Scalia joined. Justice Alito filed a dissenting opinion, in which Justice Scalia joined.

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