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The United States Supreme Court ruled Monday that the US Constitution forbids mandatory sentencing of life in prison without the possibility of parole for juveniles convicted of homicide. The justices ruled 5-4 in Miller v. Alabama and Jackson v. Hobbs that such a sentencing structure violates the Eighth Amendment’s rule against cruel and unusual punishment.
In one case, 14-year-old Evan Miller was convicted of murder in Alabama after setting fire to a trailer, which killed his neighbor. The second case focused on Kuntrell Jackson, who was convicted of murder in Arkansas at age 14 following his participation in an armed robbery that led to a store clerk’s death.
Both cases were sentenced using the mandatory life-without-parole penalty in their respective states, which the SCOTUS ruling struck down. The Court’s decision also invalidates similar statutes in 27 other states.
Justice Elena Kagan delivered the Opinion of the Court, citing Graham v. Florida – which determined life-without-parole sentences for non-homicides unconstitutional – as a primary precedent for the ruling. Citing Graham, the Court’s opinion asserts, “that youth matters in determining the appropriateness of a lifetime of incarceration without the possibility of parole.”
The mandatory penalty schemes currently in issue prevent sentencers from considering a juvenile offender’s youth, disregarding the foundational opinion in Graham that imposing the most severe penalties on juveniles cannot proceed as though the offenders are not children.
Justice Samuel Alito Jr. presented an abridged version of his own dissent, joined by Justice Antonin Scalia, from the bench, calling the majority’s reasoning, “the personal views of five Justices.”
Justice Alito’s dissenting opinion heavily criticizes the Court’s majority view for including individuals of such a broad age range, particularly regarding defendants closer to 18 years of age, “The category of murderers that the Court delicately calls “children” (murderers under the age of 18) consists overwhelmingly of young men who are fast approaching the legal age of adulthood. Evan Miller and Kuntrell Jackson are anomalies; much more typical are murderers like Donald Roper, who committed a brutal thrill-killing just nine months shy of his 18th birthday.”
However, the Miller v. Alabama ruling does not exclude juveniles from ever being sentenced to life in prison without parole. The same “mitigating qualities of youth” that prevent automatic life-without parole sentences are also left to the discretion of sentencers on a case-by-case basis.
The written dissent from Justice Alito addresses that aspect of the opinion as well, instead asserting that the Eighth Amendment is worded so that, “it leaves questions of sentencing policy to be determined by Congress and the state legislatures—and with good reason.”
According to the Equal Justice Initiative, the Alabama-based non-profit organization that also provided legal representation for Miller and Jackson, over 2200 individuals are currently serving life-without-parole sentences for crimes committed under the age of 18.