Summary
The Supreme Court held that the Eighth Amendment prohibits mandatory life imprisonment without parole for offenders who were under 18 when they committed homicide. Such sentencing schemes must allow the sentencer to consider the offender’s youth, attendant characteristics, and the circumstances of the offense. The Court reversed and remanded the consolidated cases involving Evan Miller and Kuntrell Jackson.
Topics
Practice areas
Questions Presented
- Whether the Eighth Amendment prohibits mandatory life imprisonment without the possibility of parole for offenders who were under 18 when they committed homicide.
- Whether individualized sentencing that permits consideration of a juvenile offender's age, youth-related characteristics, background, and the circumstances of the offense is constitutionally required before imposing life without parole.
- Whether discretion at the juvenile-transfer stage can substitute for individualized discretion at post-trial sentencing.
Holdings
- The Eighth Amendment forbids a sentencing scheme that mandates life imprisonment without the possibility of parole for a juvenile offender convicted of homicide.
- Before imposing life without parole on a juvenile homicide offender, the sentencer must have an opportunity to consider the offender's age and age-related characteristics, including immaturity, impetuosity, failure to appreciate risks and consequences, family and home environment, extent of participation in the homicide, effects of familial or peer pressure, and prospects for rehabilitation.
- The decision does not overrule or undermine Harmelin v. Michigan because Harmelin involved an adult offender and did not purport to resolve the constitutionality of mandatory life-without-parole sentences for juveniles.
Key quotations
“We therefore hold that mandatory life without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment’s prohibition on “cruel and unusual punishments.”” (at 2)
“We therefore hold that the Eighth Amendment forbids a sentencing scheme that mandates life in prison without possibility of parole for juvenile offenders.” (at 16-17)
“By requiring that all children convicted of homicide receive lifetime incarceration without possibility of parole, regardless of their age and age-related characteristics and the nature of their crimes, the mandatory sentencing schemes before us violate this principle of proportionality, and so the Eighth Amendment’s ban on cruel and unusual punishment.” (at 27)
Factual background
Both petitioners were 14 years old when they participated in homicides and were tried as adults. Jackson accompanied two other boys during an attempted robbery; a confederate shot and killed the store clerk, and Jackson was convicted under an aiding-or-accomplice theory. Miller participated in a violent assault and arson after drinking and using drugs; the victim died, and Miller was convicted of murder in the course of arson. In both cases, state law mandated life imprisonment without the possibility of parole and gave the sentencing authority no discretion to impose a lesser punishment.
Procedural history
Jackson was convicted in Arkansas of capital felony murder and aggravated robbery and received a mandatory life-without-parole sentence. His state habeas petition was dismissed, and the Arkansas Supreme Court affirmed. Miller was convicted in Alabama of murder in the course of arson after being transferred to adult court and received a mandatory life-without-parole sentence; the Alabama Court of Criminal Appeals affirmed and the Alabama Supreme Court denied review. The Supreme Court granted certiorari, reversed both judgments, and remanded.
Remand instructions
The cases were remanded for further proceedings not inconsistent with the opinion, including resentencing under procedures that permit consideration of the petitioners' youth and attendant characteristics before imposing life without parole.