On June 25, 2012, the U.S. Supreme Court concluded that holding juvenile murderers for life without parole is unconstitutional under the Eight Amendment. It prohibits “cruel and unusual punishment” and “guarantees individuals the right not to be subjected to excessive sanctions.” In both, Miller v. Alabama and Jackson v. Hobbes, the Supreme Court granted certiorari to hear these cases, specifically on the constitutionality of statutory mandated punishment of life without parole.

Background: Miller v. Alabama

Petitioner Miller, a 14-year-old boy, along with a friend, assaulted and set fire to a neighbor’s trailer, who ultimately died as a result. Miller was tried as an adult for murder in the course of arson and was found guilty by a jury. The trial court imposed the statutorily mandated punishment of life without the possibility of parole.

Background: Jackson v. Hobbes

Petitioner, Jackson, was 14-years-old when he joined two other boys to rob a video store. Jackson stayed outside while the other two boys robbed the store and eventually shot and murdered the store clerk. Although Jackson stayed outside for a majority of the robbery, under the felony-murder rules of criminal procedure, “death that results from the commission of an enumerated felony (arson, rape, robbery, or burglary) constitutes first-degree murder for which the maximum penalty is death or life imprisonment. The felony-murder rule authorizes strict liability for a death that results from commission of a felony.” Therefore, Jackson was considered a co-conspirator and charged equally as if he pulled the trigger himself. Arkansas charged Jackson as an adult, based on their discretion granted in Ark. Code Ann §9-27-318(c)(2) (1998), for capital felony murder and aggravated robbery. The jury found him guilty on both counts and he was served with the statutorily mandated sentence of life imprisonment without the possibility of parole.

Justices Decisions:

Justice Kagan delivered the opinion of the Court, in which Justices Kennedy, Ginsburg, Breye, and Sotomayor joined. Justice Breyer filed a concurring opinion. Chief Justice Robets filed a dissenting opinion, in which Justices Scalia, Thomas and Alito joined.

Reasoning:

Precedent with regards to proportionate punishment was created in this decision. Based on previous rulings, Roper v. Simmons and Graham v. Florida, these cases paved the reasoning for today’s decision. Roper already held that the Eighth Amendment bars capital punishment for children based on their “lack of maturity” and “underdeveloped sense of maturity.” Graham held that the Eighth Amendment prohibits a sentence of life without parole for a juvenile convicted of a non-homicide offense. These cases are important to create today’s line of reasoning because they enacted the concept that sentencing authorities must consider the details of the case and characteristics of the defendant (i.e. age) before sentencing him to death. Since these boys were juveniles, the court further used Hamelin v. Michigan to support the idea that “sentencing practices that are permissible for adults, may not be so for children.” Ultimately, these two cases proved support that a statutory mandate on sentencing denied the petitioners proportional sentencing to their circumstance and age.

Take-Away:

The main issue that the Court had is that in neither case did the sentencing authority have any discretion to impose a different punishment. The Court does not say that all juveniles should never be sentenced to life without parole, but a sentencer follow a certain process of discretion in choosing the sentence, so that the juvenile offenders are punished proportional to their crime. The Court ultimately found that the mandatory statutorily imposed life without parole was in fact an “excessive sanction” according to the Eighth Amendment.