Miller v. Alabama

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Following is the case brief for Miller v. Alabama, 567 U.S. Supreme Court (2012).

Case Summary of Miller v. Alabama:

  • This case involves two companion cases.  In both cases, a 14-year-old was convicted of murder and sentenced to a mandatory term of life in prison without parole.
  • Both defendants argued that a sentence of life without parole for a juvenile violates the Eighth Amendment’s prohibition of cruel and unusual punishment.
  • The U.S. Supreme Court held that the Eighth Amendment prohibits a sentencing structure that mandates a life-without-parole sentence for juveniles who have been convicted of murder.

Miller v. Alabama Case Brief

Statement of the Facts:

Evan Miller, age 14, and an accomplice killed Cole Cannon in 2003.  They killed Cannon by beating him with a baseball bat and then setting fire to his trailer home with Cannon inside.  After a trial, Miller was found guilty of murder during the course of arson.  He was sentenced to a mandatory sentence of life imprisonment without parole.

In the companion case, Kuntrell Jackson and two other accomplices, all 14 years old, robbed a video store in 1999.  During the robbery, one of Jackson’s accomplices shot and killed the store clerk with a shotgun.  After a trial, Jackson was found guilty of capital felony murder.  Like Miller, Jackson was sentenced to a mandatory sentence of life imprisonment without parole.

Procedural History:

Miller filed a motion for a new trial, arguing that his sentence violated the Eighth Amendment’s prohibition of cruel and unusual punishment.  The Alabama Court of Criminal Appeals affirmed the trial court’s denial of that motion.  The Alabama Supreme Court denied review of the case.

Jackson filed a state petition for habeas corpus in the Arkansas circuit court, arguing that his sentence violated the Eighth Amendment.  The circuit court dismissed the petition.  The Arkansas Supreme Court affirmed that decision.

The U.S. Supreme Court granted certiorari in both cases.

Issue and Holding:

Does a mandatory sentence of life without parole for a juvenile homicide offender violate the Eighth Amendment’s prohibition of cruel and unusual punishment?  Yes.

Judgment:

The judgments of the Alabama Court of Criminal Appeals and the Arkansas Supreme Court are reversed.

Rule of Law or Legal Principle Applied:

A mandatory sentence of life without parole for juvenile homicide offenders violates the Eighth Amendment’s ban on cruel and unusual punishment.

Reasoning:

The prohibition of “cruel and unusual punishment” under the Eighth Amendment comes from the notion that a punishment must be proportionate to the offense and the offender.  In that vein, the Court has already held that the Eighth Amendment prohibits the death penalty for juvenile offenders (Roper v. Simmons, 543 U.S. 551 (2005)), and prohibits a life-without-parole sentence for juvenile non-homicide offenders (Graham v. Florida, 560 U.S. 48 (2010)).

The reasoning behind Roper and Graham applies with equal force in the present case.  Juveniles are different from adults for criminal sentencing purposes.  A child’s lack of maturity leads to needless risk-taking and impulsivity, yet it also allows for a better chance of rehabilitation.  In addition, a mandatory life-without-parole sentence takes away a court’s ability to account for a juvenile offender’s youth and family/home environment when imposing sentence.

Dissenting Opinion (Roberts):  

A mandatory sentence of life without parole cannot be described as “unusual” when a majority of states support such sentencing schemes.  While crimes committed by juveniles is tragic on many levels, neither the Constitution nor the Court’s precedent prohibits mandatory life-without-parole sentences for juvenile homicide offenders.

Dissenting Opinion (Thomas):

The majority relies on Roper and Graham to reach its conclusion.  Those precedents and the majority’s own sense of morality, however, do not comport with the original understanding of the Eighth Amendment’s ban on cruel and unusual punishment.

Dissenting Opinion (Alito):

The Court’s opinion improperly takes authority away from the democratic decisions of state legislatures.

Significance:

Miller v. Alabama follows from Graham’s holding that sentencing a juvenile to life without parole for crimes, except murder, is unconstitutional.  What is important to note, however, is that this case still allows for life-without-parole sentences for juvenile murderers.  The key is that such sentences cannot be mandatory.

Student Resources:

https://www.oyez.org/cases/2011/10-9646

https://www.supremecourt.gov/opinions/11pdf/10-9646g2i8.pdf

http://jjie.org/2016/03/18/long-after-landmark-decision-evan-miller-still-waits-for-resentencing/