Montgomery v. Louisiana
Following is the case brief for Montgomery v. Louisiana, 136 S. Ct. 718 (2016)
Case Summary of Montgomery v. Louisiana:
- In 1963, 17-year-old Montgomery killed a deputy sheriff in Louisiana. He was convicted and received a mandatory life-without-parole sentence.
- In 2012, the Supreme Court decided Miller v. Alabama, which held that a mandatory life-without-parole sentence for a juvenile violates the Eighth Amendment.
- Accordingly, Montgomery sought post-conviction review of his sentence, arguing that his sentence is now illegal based on Miller.
- The Louisiana Supreme Court had previously held that Miller did not apply retroactively, and thus did not hear Montgomery’s case.
- The U.S. Supreme Court reversed and remanded. It held that Miller announced a substantive rule of constitutional law, and therefore applies retroactively.
Montgomery v. Louisiana Case Brief
Statement of the Facts:
In 1963, 17-year-old Montgomery killed a deputy sheriff in Louisiana. He was convicted, and the verdict resulted in an automatic life-without-parole sentence. Almost 50 years later, in 2012, the Supreme Court decided Miller v. Alabama, 567 U.S. 460 (2012), which held that a mandatory life-without-parole sentence for juvenile homicide offenders violated the Eighth Amendment’s prohibition of cruel and unusual punishment.
Given the decision in Miller, Montgomery moved for a finding that his mandatory life-without-parole sentence was illegal.
Procedural History:
- The state trial court denied Montgomery’s motion.
- The Louisiana Supreme Court refused to hear the appeal, noting that it had previously held that Miller does not apply retroactively in state court.
- The U.S. Supreme Court granted certiorari.
Issues and Holdings:
- Does the U.S. Supreme Court have the jurisdiction to review the Louisiana Supreme Court’s determination on retroactivity?
- Does Miller apply retroactively to those convicted before Miller was decided?
Judgment:
The decision of the Louisiana Supreme Court is reversed and remanded.
Rule of Law or Legal Principle Applied:
- If the Constitution prohibits a State from keeping someone in jail who was released on federal habeas review, then a State cannot constitutionally keep someone in jail following the State’s own post-conviction proceedings.
- Miller announced a new substantive rule of constitutional law. Therefore, Miller must apply retroactively in cases on state collateral review.
Reasoning:
When the Court establishes a substantive rule of constitutional law, it must apply retroactively. That is because it deals with a substantive constitutional right that goes beyond procedural guarantees. If a State court fails to recognize a substantive rule, it is reviewable because failure to recognize such a rule results in a violation of constitutional magnitude. That is not always true for failing to apply a procedural rule.
In Miller, the Court recognized a substantive rule of constitutional law in finding that a mandatory life-without-parole sentence for juvenile homicide offenders violated the Eighth Amendment. Accordingly, a State must also apply the rule retroactively, otherwise Montgomery’s sentence is an illegal sentence under the Constitution.
Concurring and Dissenting Opinions:
Dissenting Opinion (Scalia):
The Court cases relied on by the majority were not binding and did not directly address the present case. Further, the language in Miller itself stated that it did not create a substantive rule, but rather recognized a process requiring an individualized review of a juvenile’s case before imposing a life-without-parole sentence. Finally, Miller still allowed for a life-without-parole sentence for a juvenile, just not a mandatory one.
Dissenting Opinion (Thomas):
The Court lacked the jurisdiction to hear this case. The Court cannot force States to apply constitutional rules that did not exist at the time of the conviction. There is no mechanism in the Constitution to allow the Court to require States to apply the constitutional right retroactively.
Significance:
Montgomery v. Louisiana is inextricably linked to Miller v. Alabama. Miller essentially recognizes the constitutional prohibition of mandatory life without parole for juveniles, and Montgomery makes that apply retroactively. Consequently, there were a number of cases filed following Montgomery where defendants asked courts to revisit old mandatory life-without-parole sentences.
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