Jones v. Mississippi

Supreme Court of the United States · 2021 · Federal Courts

Federal CourtsEighth Amendmentjuvenile sentencinglife without paroleMiller v. AlabamaMontgomery v. Louisianapermanent incorrigibilitydiscretionary sentencing

Facts

Jones was 15 when he killed his grandfather and was convicted of murder. At the time of his original sentencing, Mississippi law made life without parole mandatory for murder, so that sentence was imposed. After Miller, Jones received a new sentencing hearing where his attorney argued that youth diminished culpability and that the record did not support irreparable corruption. The sentencing judge acknowledged he had discretion to impose a lesser sentence, considered factors relevant to Jones's youth and culpability, and nonetheless imposed life without parole again.

Issue

When a defendant committed a homicide while under 18, do Miller v. Alabama and Montgomery v. Louisiana require the sentencer to make a separate factual finding of permanent incorrigibility, or at least provide an on-the-record explanation implicitly finding permanent incorrigibility, before imposing life without parole?

Rule

In a case involving a defendant who committed homicide while under 18, the Eighth Amendment requires that the sentence not be mandatory and that the sentencer have discretion to consider the offender's youth and impose a lesser punishment. Miller and Montgomery do not require a separate factual finding of permanent incorrigibility or an on-the-record sentencing explanation containing an implicit finding of permanent incorrigibility.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Ohio, 17-year-old Malik Turner is convicted of murder. A state statute requires the sentencing judge to impose life without parole on every person convicted of murder, regardless of age, and the judge states that Malik's youth cannot alter the sentence.

Under the Eighth Amendment rule governing juvenile homicide offenders, is Malik's sentence constitutional?

Explanation. A juvenile homicide offender may receive life without parole only if the sentence is not mandatory and the sentencer has discretion to impose a lesser punishment after considering youth. The Constitution does not require a separate incorrigibility finding, but it does forbid mandatory life-without-parole sentencing for offenders who were under 18 when they committed homicide.