Millerv.Alabama
Miller v. Alabama and the companion case Jackson v. Hobbs involved 14-year-olds convicted of homicide and sentenced to mandatory life imprisonment without parole. Evan Miller participated in a robbery, beat a neighbor with a friend, and set fire to the neighbor’s trailer; the neighbor died. Kuntrell Jackson was present during a planned robbery when a companion shot and killed a store clerk. The Supreme Court held that the Eighth Amendment forbids sentencing schemes that make life without parole mandatory for juvenile homicide offenders. Children are constitutionally different from adults because of immaturity, vulnerability to outside pressure, limited control over their environments, and less-fixed character. Those characteristics diminish the justifications for imposing the harshest punishment and require the sentencer to consider youth and its attendant circumstances before deciding whether a juvenile homicide offender should receive life without parole. The Court did not categorically bar life without parole in every juvenile homicide case; it required an individualized sentencing process. The Court rejected the States’ arguments that adult-transfer decisions, legislative practice, or Harmelin v. Michigan eliminated that requirement. The Alabama and Arkansas judgments were reversed and remanded. Justice Breyer concurred; the Chief Justice and Justices Thomas and Alito dissented in separate opinions.
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