In Miller v. Alabama, 132 S. Ct. 2455 (2012), the Supreme Court held unconstitutional roughly 2,000 life-without-parole (LWOP) sentences, which had been imposed In support of Miller, the American Psychological Association (“APA”) and others argue that youths must not be sentenced to life without parole because they are less developed and therefore, less culpable than adults. See Miller v. State, 63 So.3d 676, 682–83 (Ala. Crim. The judges further claim that sentencing a youth to life without parole actually provides disincentives to the youth to attempt to reform both because of an obvious lack of hope and because those sentenced to life without parole often have limited access to prison vocational and self-help programs. Miller points primarily to three sources as support for his argument: psychological studies of adolescent behavior, legislative history distinguishing adolescents from adults, and actual sentencing practices in the courts. Alabama further notes that many states with life-without-parole sentences for juveniles make such a sentence mandatory for certain serious crimes, which Alabama asserts both demonstrates that such punishments represent a national consensus and explains why so many minors with a life-without-parole sentence received their sentence through a mandatory statute. Reasoning that the seriousness of Miller’s capital murder crime warranted life without parole, the Alabama Court of Criminal Appeals held that Miller’s conviction was not unconstitutional, despite Miller’s age. The parties’ debate centers on differing interpretations of the Supreme Court cases of Roper v. Simmons and Graham v. Florida, the former of which held that minors cannot be sentenced to the death penalty and the latter of which held that minors cannot be sentenced to life in prison without parole for non-homicide offenses. Finally, Alabama points out that no juvenile receives a truly mandatory sentence because courts may always conduct a case-by-case review to determine whether a sentence violates the Eighth Amendment, regardless of the statutory minimum sentence. HISTORICAL BACKGROUND When Miller v. Alabama reached the Supreme Court in 2012, more than 2,500 inmates across the United States were serving sentences of life without parole for offenses perpetrated while under the age of eighteen. Does imposition of a life-without-parole sentence on a 14-year-old child convicted of homicide violate the Eighth and Fourteenth Amendments’ prohibition against cruel and unusual punishments? The Court struck down statutes in 29 states that provide for mandatory life-without-parole sentences for children, reasoning that mandatory imposition of life-without-parole sentences on children “contravenes Graham’s (and also Roper’s) foundational principle: that imposition of a State’s most severe penalties on juvenile offenders cannot proceed as though they were not children.”, “This is an important win for children. Alabama responds by arguing that, in relative terms, this seemingly small number of life sentences does not indicate a rarely accepted practice because very few juveniles commit homicidal crimes in the first place. Alabama law required that Miller initially be charged as a juvenile, but allowed the District Attorney to seek removal of the case to adult court. When Miller and Smith found none, they stole Cannon’s baseball cards and went back to Miller’s home. Certainly, according to Alabama, nothing approaching a “consensus” exists in the scientific community as to whether adolescents are inherently unfit to conform to the same standards applied to adults. After initially denying all wrongdoing, Miller signed a statement about the night’s occurrences in which he stated that he had stolen the money and driver’s license after a fight with Cannon but had not set the fire. Respondent Alabama argues in response that, contrary to Miller’s suggestion, contemporary values actually support the imposition of a life-without-parole sentence for a minor. (334) 269-1803 La corte en Miller v Alabama reconoció que los niños menores de 18 años tienen una capacidad disminuida y no pueden apreciar plenamente la naturaleza de sus acciones. While the Court did not categorically ban juvenile life without parole in all circumstances, Justice Kagan wrote for the majority that, “given all that we have said in Roper, Graham, and this decision about children’s diminished culpability, and heightened capacity for change, we think appropriate occasions for sentencing juveniles to this harshest possible penalty will be uncommon.”. At trial, the jury returned a verdict of guilty. According to Miller, this evidence strongly suggests that juries are almost universally opposed to imposing such a severe sentence on a minor. App. The Alabama Court of Criminal Appeals affirmed, holding that Miller's sentence was not overly harsh when compared to his crime, and that its mandatory nature was permissible under the Eighth Amendment. Petitioner Evan Miller argues that to sentence a 14-year-old to life without parole without considering mitigating factors, such as the defendant’s age, violates the Eighth and Fourteenth Amendments’ ban on cruel and unusual punishment. In this case, the Supreme Court will decide whether sentencing a 14-year-old to life in prison without parole violates the Eighth and Fourteenth Amendments’ prohibition against cruel and unusual punishment. As Miller put the wallet back in Cannon’s pocket, Cannon regained consciousness and attacked Miller. Miller was 14 years old at the time. Miller appealed his conviction arguing that it violated the Eighth and Fourteenth Amendments. According to Miller, studying the sentencing practices of juries sheds light on whether a mandatory sentence accords with the generally accepted practices of the citizenry. In response, the state of Alabama argues that Roper and Graham are factually distinct from this case and that national standards of decency support sentencing a minor to life imprisonment without parole for certain extreme crimes. Miller v. Alabama Jackson v. Arkansas. Miller v. Alabama Linked with: Jackson v. Hobbs Docket No. Following the finding by the Alabama Court of Criminal Appeals, Miller’s application for rehearing was denied, as was Miller’s petition for certiorari to the Alabama Supreme Court. On the night of July 15, 2003, when Petitioner Evan Miller was 14 years old, he beat and robbed his neighbor Cole Cannon. Excerpt of Miller v. Alabama. Late that evening, Cannon had arrived at Miller’s home looking for food. Miller v. Alabama Harmelin v. Michigan (1991) Under Michigan law, the crime of possession of more than 650 grams of cocaine resulted in mandatory life imprisonment without the possibility of parole. 2010). According to Alabama, this legislative evidence of sentencing statutes is the only kind of law relevant to the analysis. In the companion case, petitioner Kuntrell Jackson, along with Derrick Shields and Travis Booker, robbed a local movie sto… This decision may discourage minors sentenced to life without parole from attempting to rehabilitate, but may also more effectively deter violent crime. Miller and Jackson were convicted of homicide offenses for crimes they committed as juveniles, and both received mandatory life without parole sentences. On the night of July 15, 2003, when Petitioner Evan Miller was 14 years old, he beat and robbed his neighbor Cole Cannon. The co-defendants covered Cannon with a sheet and left his trailer. The Court took a significant step forward by recognizing the fundamental unfairness of mandatory death-in-prison sentences that don’t allow sentencers to consider the unique status of children and their potential for change,” said Bryan Stevenson, Executive Director of the Equal Justice Initiative, who represents Jackson and Miller.
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