Miller v. Alabama

Date: June 25, 2012

Citation: 567 US ‗‗‗ 2012

Issue: Eighth Amendment

Significance: In a 5–4 decision, the Supreme Court of the United States determined that sentencing a juvenile to mandatory life imprisonment without the possibility of parole violates the protection against "cruel and unusual punishment" that is provided under the Eighth Amendment. The Court cited two earlier decisions, Roper v. Simmons and Graham v. Florida, in determining that juveniles, even when convicted of capital crimes, should not be sentenced to cruel punishments because they are not adults.

Background

When Evan Miller was fourteen years old, he and Colby Smith beat to death Miller’s neighbor, Cole Cannon, in July 2003. Then they tried to cover up the crime with arson. The boys had smoked marijuana and drank alcohol with Cannon, who had just finished a drug deal with Miller’s mother. After his arrest, Miller was first held by the Lawrence County Juvenile Court because he was a minor. However, since he was being tried for a capital offense, he was moved to Lawrence County Circuit Court. During the trial, Miller was found guilty and sentenced to a mandatory term of life imprisonment without the possibility of parole. Miller filed a motion for a new trial, saying that sentencing a youth to life imprisonment without parole was a violation of his Eighth Amendment rights. His motion was denied and the Alabama Court of Criminal Appeals supported the Lawrence County Circuit Court’s decision. The state Supreme Court supported the lower court’s decision and denied Miller’s petition.

At about the same time that Miller killed Cannon, another fourteen-year-old, Kuntrell Jackson, was convicted of homicide in Blytheville, Arkansas, for an event that happened in November 1999. In Arkansas, prosecutors can charge fourteen-year-olds as adults if they have committed serious crimes. Like Miller, Jackson was sentenced to life imprisonment without parole. He also petitioned the court, which dismissed his petition. The state Supreme Court later supported the lower court’s decision. Miller was a consolidation of both appeals (Miller’s and Jackson’s).

Arguments for Miller began on March 20, 2012. Two earlier cases that were cited in the Miller decision, Roper v. Simmons (2005) and Graham v. Florida (2010), both dealt with a similar question: Should juveniles receive the same sentences as adults for the same cruel crimes, or is this a violation of the "cruel and unusual punishment" protection under the Eighth Amendment? In Roper, Christopher Simmons had been sentenced to death for a homicide in Missouri that he committed at the age of seventeen. His sentence was commuted to a life imprisonment without parole after the Supreme Court decision in Atkins v. Virginia (2002), which stated that the execution of a defendant who is mentally ill violates the Eighth Amendment. According to the Roper decision, children are different than adults when it comes to sentencing. In Graham v. Florida (2010), sixteen-year-old Terrence Graham had been convicted of a nonhomicidal crime and sentenced to life imprisonment without parole. When the case was argued in front of the Supreme Court, Justice Anthony Kennedy delivered the majority decision, which stated that sentencing a juvenile to life imprisonment without parole is a violation of the Eighth Amendment.

Opinion of the Court

In a 5–4 decision, the Supreme Court ruled that the Eighth Amendment protects children seventeen years of age and younger who are convicted of homicide from being sentenced to life imprisonment without parole. Justice Elena Kagan, writing for the majority, reversed the decisions made by the state Supreme Courts in Arkansas (Jackson v. Hobbs) and Alabama (Miller v. Alabama), saying that children are not adults and therefore cannot receive the same sentences for capital offenses. Kagan detailed:

• State law mandated that each juvenile die in prison even if a judge or jury would have thought that his youth and its attendant characteristics, along with the nature of his crime, made a lesser sentence (for example, life with the possibility of parole) more appropriate. Such a scheme prevents those meting out punishment from considering a juvenile’s "lessened culpability" and greater "capacity for change" . . . and runs afoul of our cases’ requirement of individualized sentencing for defendants facing the most serious penalties. (Federle 366)

Kagan explained that with mandatory sentences are problematic because "every juvenile will receive the same sentence as every other—the 17-year-old and the 14-year-old, the shooter and the accomplice, the child from a stable household and the child from a chaotic and abusive one." Therefore, "immaturity, impetuosity, and failure to appreciate risks and consequences" are factors in offenders under the age of eighteen who commit murder.

Chief Justice John Roberts and Justices Samuel Alito, Antonin Scalia, and Clarence Thomas dissented. Three dissenting opinions were presented but all expressed that states should make the decision about sentences for minors, ensuring that the sentence is appropriate. Roberts argued that the Court should apply the law instead of consider what is the best moral answer to the question and what is more in line with what society thinks.

Impact

The issue of minors being charged as adults for adult crimes is not new yet public opinion has changed over the last couple of decades, as evidenced in Roper, Miller, and Graham. The Court’s decision in Miller had significant implications: one, after Miller, twenty-nine states had their mandatory sentences invalidated. As a result, states had to figure out what to do with the hundreds of juvenile defenders who had been sentenced to life imprisonment without parole. Two, few states passed legislation to do away with any juvenile sentence that included life imprisonment without parole. Still, a handful of states held onto life imprisonment without parole for juveniles for certain crimes.

One of the biggest impacts of Miller happened on January 25, 2016. On this day, the Supreme Court decided in Montgomery v. Louisiana that all states must apply Miller retroactively, meaning that those people who were sentenced to death as children (and are now eighteen years of age or older) are allowed to have new hearings for sentencing. This decision affected hundreds of prisoners in states that had previously refused to apply Miller retroactively, including Louisiana, Alabama, Colorado, Pennsylvania, Michigan, and Minnesota. Thus, Miller has become a US Supreme Court landmark case in juvenile sentencing.

Bibliography

Ford, Matt. "A Retroactive Break for Juvenile Offenders." Atlantic. Atlantic Monthly, 26 Jan. 2016. Web. 8 Feb. 2016.

Federle, Katherine Hunt. Children and the Law. New York: Oxford UP, 2012. Print.

Liptak, Adam, and Ethan Bronner. "Justices Bar Mandatory Life Terms for Juveniles." New York Times. New York Times, 15 June 2012. Web. 8 Feb. 2016.

"Miller v. Alabama (10-9646)." Legal Information Institute. Cornell University Law School, n.d. Web. 8 Feb. 2016.

"Miller v. Alabama." Supreme Court of the United States. Supreme Court of the U.S., 2012. Web. 8 Feb. 2016.

Swift, James. "Miller v. Alabama: One Year Later." Juvenile Justice Information Exchange. Juvenile Justice Information Exchange, 25 June 2013. Web. 8 Feb. 2016.

"United States Supreme Court Rules Miller v. Alabama Is Retroactive." Equal Justice Initiative. Equal Justice Initiative, 25 Jan. 2016. Web. 8 Feb. 2016.

Whitehead, John T., and Steven P. Lab. Juvenile Justice: An Introduction. New York: Routledge, 2015. Print.

Zimring, Franklin E., and David S. Tanenhaus, eds. Choosing the Future for American Juvenile Justice. New York: New York UP, 2014. Print.