WASHINGTON (CN) - The Eighth Amendment forbids mandatory life sentences without the possibility of parole for juvenile murderers, the divided U.S. Supreme Court ruled Monday.
In each of the cases consolidated as Miller v. Alabama, a 14-year-old was convicted of murder and sentenced to a mandatory term of life imprisonment without the possibility of parole.
In the first of the consolidated cases, petitioner Evan Miller and a friend beat Miller's neighbor and set fire to his trailer after a night of drinking and drug use. The neighbor died.
Miller was initially charged as a juvenile, but his case was removed to adult court, where he was charged with murder in the course of arson. A jury found him guilty, and the trial court imposed a statutorily mandated punishment of life without parole. The Alabama Court of Criminal Appeals affirmed, holding that Miller's sentence was not overly harsh when compared to his crime.
In the second case, the petitioner, Kuntrell Jackson, accompanied two other teens to a video store they intended to rob. It was only once they were on the way, the petitioner said, that he learned one of other boys was carrying a shotgun.
According to the High Court's synopsis of the case, Jackson stayed outside the store for most of the November 1999 robbery, but after he entered, one of his co-conspirators shot and killed store clerk Laurie Troup.
Jackson was charged as an adult with capital felony murder and aggravated robbery, and a jury convicted him of both crimes. The trial court imposed a statutorily mandated life-without-parole term. Jackson filed a state habeas petition, arguing the sentence violated his Eighth Amendment rights. Disagreeing, the court granted the state's motion to dismiss. The Arkansas Supreme Court affirmed.
The Eighth Amendment prohibits cruel and unusual punishment and guarantees individuals the right not to be subjected to excessive sanctions.
Writing for the majority in the U.S. Supreme Court, Justice Elena Kagan found that Miller brought together two strands of precedent reflecting concerns over proportionate punishment. The first has adopted categorical bans on sentencing practices based on mismatches between the culpability of a class of offenders and the severity of a penalty.
She noted that several cases in this category specifically focused on juvenile offenders because of their lesser culpability.
Roper v. Simmons, for instance, held that the Eighth Amendment bars capital punishment for children; Graham v. Florida concluded that the amendment prohibits a sentence of life without the possibility of parole for a juvenile convicted of a non-homicide offenses. Graham further likened life without parole for juveniles to the death penalty, thereby evoking a second line of cases.
In those decisions, the Supreme Court required sentencing authorities to consider the characteristics of a defendant and the details of his offense before sentencing him to death.
Kagan held the confluence of these two lines of precedent leads to the conclusion that mandatory life without parole for juveniles violates the Eighth Amendment.
The first set of cases, Roper and Graham, establish that children are constitutionally different from adults for sentencing purposes, because they are generally more vulnerable to negative influences and outside pressures, and because their lack of maturity and impulsivity lead to recklessness, impulsivity and heedless risk-taking.