Miller v. Alabama
Supreme Court of the United States
March 20, 2012, Argued; June 25, 2012, Decided
Nos. 10-9646 and 10-9647
[*465] Justice Kagan delivered the opinion of the Court.
The two 14-year-old offenders in these cases were convicted of murder and sentenced to life imprisonment without the possibility of parole. In neither case did the sentencing authority have any discretion to impose a different punishment. State law mandated that each juvenile die in prison even if a judge or jury would have thought that his youth and its attendant characteristics, along with the nature of his crime, made a lesser sentence (for example, life with the possibility of parole) more appropriate. Such a scheme prevents those meting out punishment from considering a juvenile's “lessened culpability” and greater “capacity for change,” Graham v. Florida, 560 U.S. 48, 68, 74, 130 S. Ct. 2011, 176 L. Ed. 2d 825 (2010), and runs afoul of our cases' requirement of individualized sentencing [****10] for defendants facing the most serious penalties. We therefore hold that mandatory life without parole for those under the age of 18 at the time of their crimes violates the [***415] Eighth Amendment's prohibition on “cruel and unusual punishments.“
In November 1999, petitioner Kuntrell Jackson, then 14 years old, and two other boys decided to rob a video store. En route to the store, Jackson learned that one of the boys, Derrick Shields, was carrying a sawed-off shotgun in his coat sleeve. Jackson decided to stay outside when the two other boys entered the store. Inside, Shields pointed the gun at the store clerk, Laurie Troup, and demanded that she “give up the money.” Jackson v. State, 359 Ark. 87, 89, 194 S.W.3d 757, 759 (2004) (internal quotation marks omitted). Troup refused. A few moments later, Jackson went into the store to find Shields continuing to demand money. At trial, the parties disputed whether Jackson warned Troup that “[w]e ain't playin',” or instead told his friends, “I thought you all was playin'.” Id., at 91, 194 S.W.3d, at 760 (internal [*466] quotation marks omitted). When Troup threatened to call the police, Shields shot and killed her. The three boys fled emptyhanded. [****11] See id., at 89-92, 194 S.W.3d, at 758-760.
Arkansas law gives prosecutors discretion to charge 14-year-olds as adults when they are alleged to have committed certain serious offenses. See Ark. Code Ann. §9-27-318(c) (1998). The prosecutor here exercised that authority by charging Jackson with capital felony murder and aggravated robbery. Jackson moved to transfer the case to juvenile court, but after considering the alleged facts of the crime, a psychiatrist's examination, and Jackson's juvenile arrest history (shoplifting and several incidents of car theft), the trial court denied the motion, and an appellate court affirmed. See Jackson v. State, No. 02-535, 2003 Ark. App. LEXIS 57, 2003 WL 193412, *1 (Ark. App., Jan. 29, 2003); §§9-27-318(d), (e). A jury later convicted Jackson of both crimes. Noting that “in view of [the] verdict, there's only one possible punishment,” the judge sentenced Jackson to life without parole. App. in No. 10-9647, p. 55 (hereinafter Jackson App.); see Ark. Code Ann. §5-4-104(b) (1997) (“A defendant convicted of capital murder or treason shall be sentenced to death or life imprisonment without parole”). Jackson did not challenge the sentence on appeal, and the Arkansas Supreme [****12] Court affirmed the convictions. See 359 Ark. 87, 194 S.W.3d 757.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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567 U.S. 460 *; 132 S. Ct. 2455 **; 183 L. Ed. 2d 407 ***; 2012 U.S. LEXIS 4873 ****; 80 U.S.L.W. 4560; 78 A.L.R. Fed. 2d 547; 23 Fla. L. Weekly Fed. S 455; 2012 WL 2368659
EVAN MILLER, Petitioner (No. 10-9646) v. ALABAMA; KUNTRELL JACKSON, Petitioner (No. 10-9647) v. RAY HOBBS, DIRECTOR, ARKANSAS DEPARTMENT OF CORRECTION
Subsequent History: On remand at, Remanded by Miller v. State, 148 So. 3d 78, 2013 Ala. Crim. App. LEXIS 89 (Ala. Crim. App., Nov. 8, 2013)
Prior History: [****1] ON WRIT OF CERTIORARI TO THE COURT OF CRIMINAL APPEALS OF ALABAMA. ON WRIT OF CERTIORARI TO THE SUPREME COURT OF ARKANSAS.
Jackson v. Norris, 2011 Ark. 49, 378 S.W.3d 103, 2011 Ark. LEXIS 44 (Ark., 2011)Miller v. State, 63 So. 3d 676, 2010 Ala. Crim. App. LEXIS 77 (Ala. Crim. App., 2010)
Disposition: Reversed and remanded.
sentence, juvenile, parole, cases, mandatory, murder, offenders, Eighth Amendment, adult, life-without-parole, death penalty, kill, nonhomicide, juvenile offender, homicide, plurality opinion, capital punishment, life sentence, circumstances, categorical, offenses, possibility of parole, youth, intent to kill, individualized sentencing, discretionary, culpability, maturity, convicted, violates
Constitutional Law, Bill of Rights, Fundamental Rights, Cruel & Unusual Punishment, Criminal Law & Procedure, Sentencing, Sentencing Alternatives, Life Imprisonment in Capital Cases, Juvenile Offenders, Trial as Adult, Prosecutorial & Reverse Waiver, Capital Punishment, General Overview, Murder, Capital Murder, Penalties, Felony Murder, Imposition of Sentence, Factors, Mitigating Circumstances