Law School Case Brief
Montgomery v. Louisiana - 136 S. Ct. 718 (2016)
Miller v. Alabama announced a substantive rule of constitutional law. The conclusion that Miller states a substantive rule comports with the principles that informed Teague v. Lane. Teague sought to balance the important goals of finality and comity with the liberty interests of those imprisoned pursuant to rules later deemed unconstitutional. Miller's conclusion that the sentence of life without parole is disproportionate for the vast majority of juvenile offenders raises a grave risk that many are being held in violation of the Constitution. Giving Miller retroactive effect, moreover, does not require states to relitigate sentences, let alone convictions, in every case where a juvenile offender received mandatory life without parole. A state may remedy a Miller violation by permitting juvenile homicide offenders to be considered for parole, rather than by resentencing them. Allowing those offenders to be considered for parole ensures that juveniles whose crimes reflected only transient immaturity—and who have since matured—will not be forced to serve a disproportionate sentence in violation of the Eighth Amendment.
Petitioner Montgomery was 17 years old in 1963, when he killed a deputy sheriff in Louisiana. The jury returned a verdict of "guilty without capital punishment," which carried an automatic sentence of life without parole. Nearly 50 years after Montgomery was taken into custody, the U.S. Supreme Court decided in Miller v. Alabama that mandatory life without parole for juvenile homicide offenders violates the Eighth Amendment's prohibition on "cruel and unusual punishments." Montgomery sought state collateral relief, arguing that Miller rendered his mandatory life-without-parole sentence illegal. The trial court denied his motion, and on appeal, his application for a supervisory writ was denied by the Louisiana Supreme Court, which had previously held that Miller does not have retroactive effect in cases on state collateral review.
Does the ruling in Miller have retroactive effect in cases on state collateral review?
According to the Court, when a new substantive rule of constitutional law controlled the outcome of a case, the Constitution required state collateral review courts to give retroactive effect to that rule. The Court therefore had jurisdiction to review the Louisiana courts' decision that the Miller rule did not apply retroactively. However, the Court posited that giving Miller retroactive effect did not require states to relitigate sentences in every case. Instead, the Court held that states could remedy Miller violations by permitting juvenile homicide offenders to be considered for parole. Judgement was reversed.
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