Miller v. Alabama; Jackson v. Hobbs
In January 2012, NJDC signed on to an amicus brief filed by Juvenile Law Center, the Center on Wrongful Convictions of Youth, and several other interested organizations, in support of Evan Miller and Kuntrell Jackson, two men convicted of homicide offenses for crimes committed as juveniles, who had each received a mandatory life without parole sentence.
The United States Supreme Court agreed to hear the two companion cases to consider the following questions:
- Does imposition of a life-without-parole sentence on a 14-year old child convicted of homicide violate the Eighth and Fourteenth Amendments’ prohibition against cruel and unusual punishments, when the extreme rarity of such sentences in practice reflects a national consensus regarding the reduced criminal culpability of young children?
- Does such a sentence violate the Eighth and Fourteenth Amendments when it is imposed upon a 14-year old who did not personally kill the homicide victim, did not personally engage in any act of physical violence toward the victim, and was not shown even to have anticipated, let alone intended, that anyone be killed?
- Does such a sentence violate the Eighth and Fourteenth Amendments when it is imposed upon a 14-year old as a result of a mandatory sentencing scheme that categorically precludes consideration of the offender’s young age or any other mitigating circumstances?
Amici argued that the imposition of life without parole sentences on juveniles violated the Eighth Amendment’s clause prohibiting cruel and unusual punishment. Juveniles are less culpable than adults due to developmental differences, as the Court had said in Roper v. Simmons and Graham v. Florida. Additionally, amici asserted that mandatory life without parole sentences precluded consideration of individual circumstances of the youth and crime. Amici further submitted that imposing a life without parole sentence on a youth for a felony murder conviction is inconsistent with the Court’s holding in Graham that juveniles who neither kill, intend to kill, or foresee that life will be taken are constitutionally ineligible for such sentences.
On June 25, 2012 the United States Supreme Court issued a favorable opinion in the cases of Miller v. Alabama and Jackson v. Hobbs, holding that mandatory life without parole for those under the age of 18 at the time of their crimes violated the Eighth Amendment’s prohibition on cruel and unusual punishment and that a judge or jury must have an opportunity to consider mitigating circumstances before imposing the harshest possible penalty for juveniles.
While the Court’s ruling does not categorically ban juvenile life without parole in all circumstances (the Court declined to reach the issue of non-mandatory JLWOP sentences), the Court noted that given “children’s diminished culpability, and heightened capacity for change, we think appropriate occasions for sentencing juveniles to this harshest possible penalty will be uncommon.” This opinion was a victory for the entire juvenile justice community as it built upon the jurisprudence on the unique vulnerabilities of children that the Court recognized in Roper, Graham, and J.D.B. v. North Carolina.
Amicus Brief Filed: January 13, 2012 (download .pdf)
Amicus Brief Discusses: Adolescent Development; Mandatory Juvenile Life Without Parole
Oral Argument: March 20, 2012 (listen here to Miller arguments) (listen here to Jackson arguments)
Decision: June 25, 2012 (download .pdf)