Brett Jones v. State of Mississippi

Summary

The Mississippi Supreme Court considered whether Miller v. Alabama applies retroactively on collateral review to a juvenile convicted of murder and sentenced to life imprisonment. The court held that Miller established a new substantive rule applicable retroactively and that Jones's mandatory sentence violated the Eighth Amendment absent consideration of juvenile characteristics and circumstances. The court vacated the sentence and remanded for resentencing consistent with its decision in Parker v. State.

Holdings

1. Miller created a new substantive rule because it prohibited the imposition of a mandatory sentence of life without parole on juvenile offenders and thereby narrowed the application of Mississippi's sentencing law to juveniles.
2. Miller applies retroactively to juvenile homicide cases that became final before Miller was decided.
3. Jones's mandatory life sentence must be vacated and the case remanded for a new sentencing hearing conducted consistently with Miller and Parker.

Questions Presented

1. Whether Miller v. Alabama created a new substantive constitutional rule.
2. Whether Miller applies retroactively to a juvenile offender's case on collateral review.
3. Whether Jones's mandatory life sentence must be vacated and the case remanded for an individualized sentencing hearing considering the characteristics and circumstances of youth identified in Miller.

Disposition

reversed_and_remanded