SCOTUS Cautions on Relief for Juvenile Killers

     WASHINGTON (CN) — Though the Supreme Court positioned a juvenile killer to challenge his life sentence Monday, two justices cautioned that states need not necessarily show leniency.
     The advice appears in various concurring opinions to a summary order remanding the Alabama case of Renaldo Chante Adams and other inmates. Justice Samuel Alito’s opinion explains in gruesome detail the “heinous murder” Adams committed in 1997 when he was 17 years old.
     Adams had broken into a house where the family had only $9 on hand, so the patriarch ran out to the ATM.
     Melissa Mills was four months pregnant. She remained at home with the knife-wielding robber and her three children while her husband, Andrew, raced to get more money.
     Adams raped Melissa at knife-point, then stabbed her to death.
     Police found Mills near the house, covered in the woman’s blood. He was still holding the blood-soaked murder weapon, as well as “nine blood-smeared dollar bills,” Alito wrote.
     His “DNA matched the semen recovered from the rape kit performed as part of Melissa Mills’ autopsy,” the ruling states.
     Alito noted that the jury who sentenced Adams to death concluded that his age did not warrant a sentence of less than death. The sentence was commuted to one of life in light of the 2005 U.S. Supreme Court case Roper v. Simmons, which held that the Eighth Amendment prohibits a death sentence for a minor.
     Adams’ latest relief stems from more recent decisions in which the Supreme Court struck down mandatory life-sentencing schemes for juveniles.
     This holding first appeared in the 2012 case Miller v. Alabama, and the court applied it retroactively earlier this year with Montgomery v. Louisiana.
     Alito’s opinion, joined by Justice Clarence Thomas, specifies how the “present case differs from most” other post-Montgomery remands.
     “In cases like this, it can be argued that the original sentencing jury fulfilled the individualized sentencing requirement that Miller subsequently imposed,” he wrote.
     Since the jury who sentenced Adams to death “necessarily rejected the argument that the defendant’s youth and immaturity called for the lesser sentence of life imprisonment without parole,” Alito said the state can still show that they likewise would “have felt that the defendant’s youth and immaturity did not warrant an even lighter sentence that would have allowed the petitioner to be loosed on society at some time in the future.”
     “In short, it can be argued that the jury that sentenced petitioner to death already engaged in the very process mandated by Miller and concluded that petitioner was not a mere ‘child’ whose crimes reflected ‘unfortunate yet transient immaturity,’ but was instead one of the rare minors who deserves life without parole,” Alito concluded.
     He said the court is free on remand to evaluate whether any further individualized consideration is required in a case like this where the “juvenile offender was originally sentenced to death after the sentencer considered but rejected youth as a mitigating factor.”
     Justice Sonia Sotomayor took issue with Alito’s advice.
     “Standards of decency have evolved since the time petitioners were sentenced to death,” she wrote, joined by Justice Ruth Bader Ginsburg. “That petitioners were once given a death sentence we now know to be constitutionally unacceptable tells us nothing about whether their current life-without-parole sentences are constitutionally acceptable. I see no shortcut: On remand, the lower courts must instead ask the difficult but essential question whether petitioners are among the very ‘rarest of juvenile offenders, those whose crimes reflect permanent incorrigibility.'”
     Alito also joined a more brief concurring opinion by Thomas that directs courts to understand on remand “that the court’s disposition of this petition does not reflect any view regarding petitioner’s entitlement to relief.”
     Thomas said lower courts must still consider, for example, “whether an adequate and independent state ground bars relief, whether petitioner forfeited or waived any entitlement to relief (by, for example, entering into a plea agreement waiving any entitlement to relief), or whether petitioner’s sentence actually qualifies as a mandatory life without parole sentence.”

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