Supreme Court: Retroactive Application of Unconstitutionality of Mandatory Life without Parole in Juvenile Cases
On January 26, 2016, the Supreme Court of the United States announced that its hallmark decision invalidating mandatory life without prison is fully retroactive. Hundreds of convicted juvenile murderers who have been given mandatory life sentences without parole for crimes they committed as juveniles will have an opportunity to seek reduced sentences or apply for parole. The Texas Court of Criminal Appeals was ahead of the curve and recognized the retroactive effect last year.
In 2012, the Supreme Court held in Miller v. Alabama that a sentence of mandatory life without parole for juvenile homicide offenders violates the Eighth Amendment’s prohibition on “cruel and unusual punishment.”
On January 25, 2016 the Supreme Court decided that their ruling in Miller was a substantive rule that, under the Constitution, is retroactive in cases on state collateral review. Though states still have the right to uphold the life sentences, they can no longer be mandatory.
This decision stems from a ruling by the Supreme Court of Louisiana in the case of Montgomery v. Louisiana. Montgomery was 17 when he killed a deputy sheriff in Louisiana. The jury returned a verdict of “guilty without capital punishment,” which carried an automatic sentence of life without parole. Then Miller v. Alabama came along and held that automatic life without parole for a juvenile was unconstitutional under the Eighth Amendment right against cruel and unusual punishment. Montgomery then sought state collateral relief, but the trial court denied his motion and the Louisiana Supreme Court, which had previously held that Miller does not have retroactive effect in cases on state collateral review, denied his application for a supervisory writ.
Montgomery has spent 46 years in prison knowing he was condemned to die in prison. After being sent to the state penitentiary at Angola, he helped started a boxing team, worked in a silkscreen department, and counseled other inmates.
The Supreme Court’s decision provided that when a new substantive rule of constitutional law controls the outcome of a case, the “Constitution requires state collateral review courts to give retroactive effect to that rule.” The Court further stated that such substantive rules place certain criminal laws and punishments altogether beyond the State’s power to impose.
The Court discussed that the foundation for the Miller analysis was derived from the line of precedents that held certain punishments were disproportionate when applied to juveniles. It further discussed that children differed from adults because they had less culpability and greater chances of reform and that imposing life without parole on juveniles was less justified when these distinctions were considered. However, the Court in Miller did recognize there were rare instances where a juvenile offender’s crime could reflect irreparable corruption.
Finally, the Court provided that a State may remedy a Miller violation by extending parole eligibility to juvenile offenders. This would not be overly burdensome on the State, and would not disturb the finality of convictions. Most importantly, it would give juvenile offenders like Montgomery the opportunity to prove “that children who commit heinous crimes are capable of change.”