Miller v. Alabama
| Miller v. Alabama | |
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| Argued March 19, 2012 Decided June 24, 2012 |
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| Full case name | Evan Miller, Petitioner v. Alabama; Kuntrell Jackson, Petitioner v. Ray Hobbs, Director, Arkansas Department of Correction |
| Docket nos. |
10-9646 10-9647 |
| Citations | 567 U.S. ___ (more) |
| Prior history |
conviction affirmed sub nom. Miller v. State, 2010 WL 2546422 (Ala. Crim. App. June 25, 2010); rehearing denied, and new decision published, 63 So.3d 676 (Ala. Crim. App. August 27, 2010); certiorari denied sub nom. Ex parte Miller, unpub. n°1091663 (Ala. October 22, 2010); certiorari granted, 565 U. S. ___ (2011) |
| Holding | |
| The Eighth Amendment prohibits a sentencing scheme that requires life in prison without the possibility of parole for juvenile homicide offenders. | |
| Court membership | |
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| Case opinions | |
| Majority | Kagan, joined by Kennedy, Ginsburg, Breyer, Sotomayor |
| Concurrence | Breyer, joined by Sotomayor |
| Dissent | Roberts, joined by Scalia, Thomas, Alito |
| Dissent | Thomas, joined by Scalia |
| Dissent | Alito, joined by Scalia |
| Laws applied | |
| U.S. Const. Amend. VIII | |
conviction affirmed sub nom. Miller v. State, 2010 WL 2546422 (Ala. Crim. App. June 25, 2010); rehearing denied, and new decision published, 63 So.3d 676 (Ala. Crim. App. August 27, 2010); certiorari denied sub nom. Ex parte Miller, unpub. n°1091663 (Ala. October 22, 2010); certiorari granted, 565 U. S. ___ (2011)
Miller v. Alabama, 567 U.S. 460 (2012), was a United States Supreme Court case in which the Court held that mandatory sentences of life without the possibility of parole are unconstitutional for juvenile offenders. The ruling applied even to those persons who had committed murder as a juvenile, extending beyond the Graham v. Florida (2010) case, which had ruled juvenile life without parole sentences unconstitutional for crimes excluding murder.
The decision of the court was based on two consolidated cases, Jackson v. Hobbs, No. 10-9647, and Miller v. Alabama, No. 10-9646. The Los Angeles Times wrote: "In one case that came before the court, Kuntrell Jackson was 14 when he and two other teenagers went to a video store in Arkansas planning to rob it. He stayed outside, and one of the youths pulled a gun and killed the store clerk. Jackson was charged as an adult and given a life term with no parole. In the second case, Evan Miller, a 14-year-old from Alabama, was convicted of murder after he and another boy set fire to a trailer where they had bought drugs from a neighbor. He too was given a life term with no parole."
Jackson waited outside the store for a time, but entered shortly before Derrick Shields shot the store clerk. There is debate as to whether he told the clerk, "We ain't playin'" or whether he said to his accomplices, "I thought you all was playin'." Jackson was not the shooter.
Evan Miller committed homicide in the act of robbing his neighbor, Cole Cannon. Cannon had fallen asleep after he, Miller, and Colby Smith had indulged in alcohol and marijuana. Cannon awoke as Miller was replacing his (Cannon's) wallet, and Smith hit Cannon with a baseball bat. Miller took up the bat and proceeded to severely beat Cannon. Smith and Miller later returned to destroy the evidence of what they had done by setting fire to Cannon's trailer. Cannon died of severe injuries and smoke inhalation.
Justice Elena Kagan wrote for the majority of the court "that mandatory life without parole for those under age of 18 at the time of their crime violates the 8th Amendment’s prohibition on cruel and unusual punishments." “Mandatory life without parole for a juvenile precludes consideration of his chronological age and its hallmark features — among them, immaturity, impetuosity, and failure to appreciate risks and consequences,” Justice Kagan said. “It prevents taking into account the family and home environment that surrounds him — and from which he cannot usually extricate himself — no matter how brutal or dysfunctional.”
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