The plaintiffs (petitioners) are Evan Miller and Kuntrell Jackson against the State of Alabama and Ray Hobbs, Director of the Arkansas Department of Correction (respondents) respectively.
The two cases Miller vs Alabama and Jackson vs Hobbs both were cases of juvenile crimes where the defendants were sentenced as a juvenile or moved to adult court. Both were sentenced to life without parole. The procedural history of Miller vs Alabama began in July 2003 after the juvenile, Miller, defendant, was arrested and tried as an adult in the Lawrence County Circuit Court for capital murder during the course of an arson. Miller was indicted in 2006 by the jury and sentenced to a lifetime in jail without the possibility of parole. After the case, Miller filed for a new trial. Due to his juvenile status at the time of the crime, he believed that the sentence without parole was unconstitutional since he argued it was cruel and unusual punishment, which violated the eighth amendment. Miller’s petition for a new trial was denied, and the Alabama Court of Criminal Appeals upheld the rejection of the new trial. The Supreme Court of Alabama denied Miller's petition for writ of certiorari, (when a higher court orders a lower court to deliver its record in a case so that the higher court may review it).
The procedural history of the companion case to Miller vs Alabama, Jackson vs Hobbs, petitioner Kuntrell Jackson was tried and convicted of capital murder and aggravated robbery in July of 2003. The state sentenced Jackson to a mandatory life sentence without the possibility of parole. In 2008, Jackson also appealed stating that his sentence was in violation of the eighth and fourteenth amendments due to unusual and excessive punishment; however, the circuit court and the Supreme Court of Arkansas upheld the court’s decision. This paired case comes on the heels of three other cases sent before the Supreme Court regarding juvenile offenders: Roper v. Simmons, 543 U.S. 551, (2005), Graham v. Florida, 560 U.S. 48, 2010 and Montgomery v. Louisiana, 577 U.S. ___ (more) 136 S. Ct. 718, 193 L. Ed. 2d 599.
The specific circumstances of the Miller vs Alabama case began in July 2003 when defendant Evan Miller, alongside peer (Smith) killed Miller’s neighbor (Cannon) with a baseball bat and burned Cannon’s trailer home. The three boys/men had been drinking and smoking marijuana leading up to the event. Miller was 14 at the time of the crime and was arrested and tried as an adult in the Lawrence County Circuit Court for capital murder during the course of an arson. Miller was indicted in 2006 by the jury and sentenced Miller to a lifetime sentence without the possibility of parole. As stated above in the procedural history, Miller filed for a new case but was denied by Alabama Court of Criminal Appeals and then that decision was upheld by the Supreme Court of Alabama.
The companion case Jackson vs. Hobbs had similar specific facts where Kuntrell Jackson, along with two juvenile peers robbed a local convenience store in Blytheville, Arkansas in November, 1999. All three boys were 14 years old at the time of the offense. Jackson learned on the way to the robbery that one of the boys was carrying a shot gun. During the majority of the robbery, Jackson remained outside but when the sales clerk refused to give up the the money, Jackson entered the store and one of his peers shot and killed the clerk. Jackson was tried and convicted of capital murder and aggravated robbery in July of 2003. He appealed and similar to Miller, he was not granted his appeal and the Supreme Court of Arkansas upheld the decision. The claim by the plaintiff is that due to his juvenile status at the time of the crime in 2003, the possibility without parole was unconstitutional since it was cruel and unusual punishment for a minor. Miller argued that this violated his eighth amendment rights which prohibits the federal government from imposing excessive bail, excessive fines or cruel and unusual punishment. Miller challenged the state on his punishment. The constitutional basis in which the case is grounded is the eighth amendment, and whether or not life without the possibility of parole is unconstitutional for juvenile offenders. The Supreme Court ruled 5-4 in favor of Evan Miller.
The justices voted 5-4 in favor of Miller. The justices who voted in the majority were justices Kagan, Sotomayor, Breyer, Kennedy and Ginsberg. Justices Alito, Thomas, Scalia and Roberts dissented. Justice Kagan argued for the majority and reversed the Arkansas and Alabama Supreme Courts’ decisions stating that children are constitutionally different from adults, and that the the life sentence without parole would indeed violate juveniles’ eighth amendment rights and be a cruel and unusual punishment. Justice Breyer concurred with Justice Kagan’s statement and went on to say that there was little way to determine that Miller actually killed or intended to kill the neighbor. The major dissent was given by Justice Roberts who argued on behalf of the other dissenters, to state that the court’s role is to interpret the law and not question the morality and social issues behind it. The dissent also argued that the majority did not provide sufficient information as to why the punishment given to Miller (and Jackson) was cruel and unusual (thus potentially not violating the eighth amendment rights). Justices Thomas and Scalia and justices Alito and Scalia also provided supporting dissents.
The reasoning behind the ruling was that the Supreme Court found that children were epistemologically different due to lesser developed brains than adults and thus should not be given the adult life sentence without parole. The final ruling struck down the Arkansas and Alabama Supreme Courts’ decisions. Justice Kagan eloquently stated, “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.” This supreme court decision applies retroactively to all juvenile offenders who committed crimes under 18 with a life sentence without parole. Although it applies retroactively, it is still up to the court to determine whether or not the offender’s youth played a part in the criminal act.
The Miller vs Alabama case impacts all governments and judges who have ruled on juvenile offenders and did not consider the age of the offender when judging the crime. The supreme court’s decision argued that judges need to examine all circumstances of the case, including age and youthfulness, otherwise sentencing a juvenile to life in prison without parole violates their eight amendment rights. The ruling especially affects the judicial branch since it requires judges to retroactively consider the offenders age at the time of the crime, with the exception of murder. This ruling only affects the twenty-six states and federal government cases which require mandatory minimum sentences for juveniles. Courts of all levels, district, circuit and supreme, will have to consider resentencing for juveniles convicted prior to the Miller vs Alabama’s win for children.
The case also has implications for the legislative and executive branches of government. Since President Reagan’s staunch Anti-Drug act in 1986 and subsequently his administration’s policy focus on cracking down on drugs, there has been a continued tough stance on crime through the U.S. This case breaks away from that standpoint and forces policymakers to shift policies away from supporting life without parole. Regardless of political stance, policy makers and courts will have to change the language of bills and existing laws which allow for mandatory life without parole for juveniles. However, not all states will be changing laws and policies as quickly, since the Supreme Courts of Pennsylvania, Michigan and Louisiana, where 60% of all juveniles serving life sentence are, did not find Miller vs Alabama retroactive.
After the Miller vs Alabama, 567 U.S. 460 (2012), case many news outlets reported personal accounts, ways the verdict would affect high profile cases, potential changes, and implications moving forward. In May of 2017, the New York Times published an article, “Lee Boyd Malvo, Serving Life in ‘Beltway Sniper’ Case, Must Be Resentenced, Judge Says,” directly relating the high-profile Beltway Sniper case, in which Malvo, a juvenile, 17 years old at the time of the crimes, was served a life sentence without parole. The judge in the case said, “it is doubtful that there exists a public policy more foundational than those safeguarding the constitutional due process by which the state deprives citizens of their life and liberty.” This decision to resentence Malvo caused a massive public reaction of outrage since the crimes still resonate in the communities affected. Although Malvo was only convicted of one count of murder, (his adult accomplice killed 10 and was executed in 2009), the randomness of locations, and victims caused mass panic and fear across the D.C., Maryland and Virginia area in 2002.
In my own opinion, the court reached a fair result in Miller vs Alabama. There is a plethora of individuals punished for actions they made as juveniles, and thirty to fifty years later they are still being punished behind bars when they could be considered rehabilitated. There is a great need in our court system to recognize that juvenile mistakes can have a definitive punishment that does not need to be life without parole. However, as a longtime resident of the D.C. metro area, I am agonizingly aware of the pain the Beltway Sniper caused my community and shaped my school experiences. Despite emotions I agree with the court majority that children are different than adults and life sentence without parole is an unusual punishment. I disagree with the dissent that it is not the court’s role to determine morality and social justice, since legislature and policy is based upon the court’s decisions so whether the justices like it or not they are indeed determining morality and justice for juveniles and beyond.