Jones v. Mississippi - 141 S. Ct. 1307 (2021)

Rule:

In Montgomery v. Louisiana, the Supreme Court unequivocally stated that Miller v. Alabama did not impose a formal fact finding requirement and added that a finding of fact regarding a child's incorrigibility is not required. In a case involving an individual who was under 18 when he or she committed a homicide, a state's discretionary sentencing system is both constitutionally necessary and constitutionally sufficient.

Facts:

A Mississippi jury convicted petitioner Brett Jones of murder for killing his grandfather. Jones was 15 years old when he committed the crime. Under Mississippi law at the time, murder carried a mandatory sentence of life without parole. The trial judge duly imposed that sentence, which was affirmed on direct appeal. This Court subsequently decided Miller v. Alabama, 567 U. S. 460, 132 S. Ct. 2455, 183 L. Ed. 2d 407, which held that the Eighth Amendment permitted a life-without-parole sentence for a defendant who committed a homicide when he or she was under 18, but only if the sentence was not mandatory and the sentencer therefore has discretion to impose a lesser punishment. In the wake of that decision, the Mississippi Supreme Court ordered that Jones be resentenced in accordance with Miller. At the resentencing, the sentencing judge acknowledged that he had discretion under Miller to impose a sentence less than life without parole. The judge determined, however, that life without parole remained the appropriate sentence for Jones. Jones again appealed his sentence, citing both Miller and the then-recently decided case of Montgomery v. Louisiana, 577 U. S. 190, 136 S. Ct. 718, 193 L. Ed. 2d 599, which held that Miller applied retroactively on collateral review. Jones contended that, under Miller and Montgomery, a sentencer must make a separate factual finding that a murderer under 18 was permanently incorrigible before sentencing the offender to life without parole. The Mississippi Court of Appeals rejected Jones’s argument. 

Issue:

Under Miller and Montgomery, must a sentencer make a separate factual finding that a murderer under 18 was permanently incorrigible before sentencing the offender to life without parole? 

Answer:

No.

Conclusion:

The Court affirmed the judgment of the appellate court, holding that a state's discretionary sentencing system was both constitutionally necessary and constitutionally sufficient. The Court's precedents did not require an on-the-record sentencing explanation with an implicit finding of permanent incorrigibility. According to the Court, Miller v. Alabama did not require the sentencer to make a separate finding of permanent incorrigibility before imposing a life-without-parole sentence. Moreover, Montgomery v. Louisiana did not purport to add to Miller's requirements. The Court held that because the Constitution dud not require an on-the-record explanation of mitigating circumstances by the sentencer in death penalty cases, it would be incongruous to require an on-the-record explanation of the mitigating circumstance of youth by the sentencer in life-without-parole cases.