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Miller v. Alabama

Supreme Court of the United States · 2012 · Criminal Procedure

Criminal ProcedureConstitutional LawEighth Amendmentmandatory LWOPjuvenile homicideindividualized sentencingEighth Amendmentcruel and unusual punishment

Facts

The cases involved two 14-year-old offenders who received mandatory sentences of life imprisonment without the possibility of parole for homicide offenses. In Jackson’s case, he was convicted under an aiding-and-abetting theory in a robbery that turned into a killing, and the State did not argue that he fired the fatal shot or intended the victim’s death. In Miller’s case, he participated in a vicious murder after consuming drugs and alcohol with the adult victim, and the record described a severely abusive and unstable family background. In both cases, the sentencing schemes made youth and its related circumstances legally irrelevant by requiring life without parole automatically upon conviction.

Issue

Does the Eighth Amendment forbid a sentencing scheme that mandates life imprisonment without the possibility of parole for juvenile offenders convicted of homicide? More specifically, must a sentencer have the opportunity to consider a juvenile’s youth and attendant characteristics before imposing that punishment?

Rule

The Eighth Amendment forbids a sentencing scheme that mandates life in prison without possibility of parole for juvenile offenders. Before imposing that harshest prison sentence on a juvenile, the sentencer must have the opportunity to consider the offender’s youth and its attendant characteristics, including age, immaturity, family and home environment, the circumstances of the offense, the extent of participation, the effects of peer or family pressure, and the possibility of rehabilitation.

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

In Ohio, a statute requires life without parole for any person convicted of aggravated murder in adult court. Sixteen-year-old Daniel Ruiz is automatically transferred to adult court, convicted, and sentenced under the statute without any separate sentencing hearing.

Under the controlling Eighth Amendment rule, is Daniel's sentence constitutional?

Explanation. The majority held that the Eighth Amendment forbids a sentencing scheme that mandates life without parole for juvenile offenders. Before that harshest prison sentence may be imposed on a juvenile, the sentencer must have an opportunity to consider youth and its attendant characteristics. Automatic transfer and a homicide conviction do not cure the constitutional defect.