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Evan Miller v. Alabama; Kuntrell Jackson v. Ray Hobbs, Director, Arkansas Department of Correction

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Evan Miller v. Alabama; Kuntrell Jackson v. Ray Hobbs, Director, Arkansas Department of Correction

Supreme Court of the United States

567 U.S. —- (2012); 132 S. Ct. 2455 (2012)

25 June 2012

Instrument(s) Cited:
Eighth Amendment to the United States Constitution (prohibition of cruel and unusual punishments)

Case Summary:

Two separate cases were decided in this appeal.

Miller, along with a friend, had beaten Miller’s neighbor and set fire to his trailer after an evening of drinking and drug use. The neighbor died. Miller was initially charged as a juvenile, but his case was later removed to adult court, where he was charged with murder in the course of arson. A jury found Miller guilty, and the trial court imposed a statutorily mandated punishment of life without parole. The Alabama Court of Criminal Appeals affirmed and the case was appealed to the United States Supreme Court.

Jackson was accompanying two other boys to a video store to commit a robbery when he learned that one of them was carrying a shotgun. Jackson stayed outside the store for most of the robbery, but after he entered, one of his co-conspirators shot and killed the store clerk. Arkansas charged Jackson as an adult with capital felony murder and aggravated robbery, and a jury convicted him of both crimes. The trial court imposed a statutorily mandated sentence of life imprisonment without the possibility of parole. Jackson filed a state habeas petition, arguing that a mandatory life-without-parole term for a 14- year-old violates the Eighth Amendment. Disagreeing, the court granted the State’s motion to dismiss. The Arkansas Supreme Court affirmed and the case was appealed to the United States Supreme Court.

Issue and resolution:
Life imprisonment of children. Whether the Eighth Amendment forbids a sentencing scheme that mandates life in prison without possibility of parole for juvenile homicide offenders. The Court ruled that the scheme violates the Eighth Amendment.

Court reasoning:
The Court said that the Eighth Amendment’s prohibition of cruel and unusual punishment guarantees individuals the right not to be subjected to excessive sanctions. That right flows from the basic precept of justice that punishment for crime should be graduated and proportioned to both the offender and the offence.

The Court reviewed its previous case law on criminal sentences for children. A previous line of Supreme court cases held that the Eighth Amendment bars capital punishment for children and also prohibits a sentence of life without the possibility of parole for a juvenile convicted of a non-homicide offence. This same line of cases has noted that life without parole for juveniles is comparable to the death penalty. A second line of Supreme Court Cases requires sentencing authorities to consider the characteristics of a defendant and the details of his offence before sentencing him to death.

Based on these two lines of cases, the Court concluded that mandatory life without parole for juveniles violates the Eighth Amendment. It was said that children must be regarded as constitutionally different from adults for sentencing purposes – their lack of maturity and underdeveloped sense of responsibility lead to recklessness, impulsivity, and heedless risk-taking. Children are also more vulnerable to negative influences and outside pressures and have limited control over their circumstances. Since a child’s character is not as well formed as an adult’s, his traits are less fixed and his actions are less likely to be evidence of the “irretrievable depravity” required for the harshest sentences, therefore, the distinctive attributes of youth diminish the penological justifications for imposing the harshest sentences on juvenile offenders, even when they commit terrible crimes.

Precedent establishes that young age matters in determining the appropriateness of a sentence. The mandatory penalty schemes at issue here, however, prevent the sentencer from considering youth and from assessing whether the law’s harshest term of imprisonment proportionately punishes a juvenile offender. The imposition of a State’s most severe penalties on juvenile offenders cannot proceed as though they were not children. Sentencers must be able to consider the mitigating qualities of youth.

Dissenting Opinions:
Judges Roberts, Scalia, Thomas, Alito:
The Eighth Amendment prohibits only “cruel and unusual punishments.” Life without parole cannot be plausibly described as “unusual,” as nearly 2,500 prisoners are serving life sentences for murders they committed before the age of 18, many of which were statutorily mandated. In addition, taking into account “objective indicia of society’s standards” and “evolving standards of decency,” as required by the Court’s precedent, supports the conclusion that the punishment is not “unusual.”

Judges Thomas, Scalia:
The precedent relied upon by the Court in reaching its conclusion is inconsistent with the original understanding of the Cruel and Unusual Punishments Clause, which was meant to apply only to methods of punishment.

Judges Alito, Scalia:
Despite claiming that its cases account for “objective indicia of society’s standards,” the Court’s trend of Eight Amendment precedent appears to increasingly ignore such indicia (as evidenced a majority of state legislatures) in favor of decreasing sentences for juvenile offenders, many of which are 17 years old and have a maturity level comparable to that of an adult. Today’s Eighth Amendment case law is no longer tied to any objective indicia of society’s standards, but is now entirely inward looking, a process of evolution which the Court is not entitled to continue.

It must be noted that this case does not prohibit life without parole for juvenile homicide offenders, only sentencing schemes which provide for mandatory life without parole.

In January 2016, the US Supreme Court ruled that this decision applies retroactively and ordered that anyone serving a mandatory juvenile life without parole sentence is considered for parole.

Prior to that, at the state level, the following courts had ruled that the Miller decision applies retroactively: District Court of Michigan, Supreme Courts of ArkansasFloridaNebraskaNew HampshireIllinoisMississippiIowaMassachusettsWyoming and South Carolina, the Court of Criminal Appeals of Texas, and US Court of Appeals for the Ninth Circuit. The following courts have ruled that Miller does not apply retroactively: US Court of Appeals for the Fifth Circuit and Eleventh Circuit and Supreme Courts of LouisianaMinnesota and Pennsylvania.

For more information on the issue of inhuman sentencing of children, including a selection of case law, please see CRIN’s ‘Inhuman sentencing’ campaign.

Link to Full Judgment:

This case summary is provided by the Child Rights International Network for educational and informational purposes only and should not be construed as legal advice.