In 5-4 Vote, Supreme Court Rules Mandatory Life Sentences for Juvenile Murderers Unconstitutional
In another 5-4 vote, the justices of the US Supreme Court ruled Monday that mandatory life sentences for juvenile murderers violate the constitution’s prohibition of cruel and unusual punishment.
In the combined cases of Miller v. Alabama and Jackson v. Hobbs, the Court’s ruling declared that the constitution bars automatically sentencing youngsters to a lifetime in prison.
Youths convicted of murder may still be sentenced to life behind bars without the possibility of parole, but judges must now consider mitigating circumstances when handing down sentences.
“The Eighth Amendment forbids a sentencing scheme that mandates life in prison without the possibility of parole for juvenile offenders,” Justice Elena Kagan wrote for the majority. “A judge or jury must have the opportunity to consider mitigating circumstances before imposing the harshest possible penalty for juveniles.”
“Our decisions rested not only on common sense — on what ‘any parent knows’ — but on science and social science as well,” Kagan wrote, adding “the mandatory penalty schemes at issue here prevent the sentencer from taking account of these central considerations.”
Indeed, studies have shown that human judgment and character are not fully developed until after age 20.
Such scientifically-based reasoning played a significant role in three earlier related Supreme Court cases. In Thompson v. Oklahoma (1988), the Court voted 5-3 to ban capital punishment for youth offenders under the age of 16. In Roper v. Simmons (2005), that ban was expanded to include all juveniles. And in Graham v. Florida (2010), the Roberts court ruled that sentencing juveniles to life without parole for crimes not involving murder was unconstitutional.
Justice Kagan was joined by Justices Stephen Breyer, Sonia Sotomayor, Ruth Bader Ginsburg and Anthony Kennedy– who also cast the fifth and deciding vote in the previous two cases involving juvenile justice– in ruling mandatory life sentences unconstitutional. Chief Justice John Roberts, along with Justices Antonin Scalia, Samuel Alito and Clarence Thomas dissented.
“Determining the appropriate sentence for a teenager convicted of murder presents grave and challenging questions of morality and social policy,” Roberts wrote in his dissent. “Our role, however, is to apply the law, not to answer such questions.”
Roberts added that mandatory life sentences “could not plausibly be described” as unusual when 29 states allow them.
He added that “the Court’s opinion suggests that it is merely a way station on the path to further judicial displacement of the legislative role in prescribing punishment for crime.”
“Perhaps science and policy suggest society should show greater mercy to young killers, giving them greater chance to reform themselves at the risk that they will kill again. But that is not our decision to make.”
The two cases at hand stem from a pair of 14-year-olds sentenced to life behind bars without parole in separate murder cases.
Evan Miller, a severely abused and suicidal Alabama teen, was convicted of killing 52-year-old neighbor Cole Cannon during a 2003 robbery in which Miller and another teen beat their victim with a baseball bat before setting his home on fire.
Kuntrell Jackson, an Arkansas teen, was convicted of killing 28-year-old video store clerk Laurie Troup during an attempted robbery in 1999.
Monday’s ruling was hailed by juvenile justice advocates.
“Juveniles will now be entitled to present mitigating evidence in support of sentences that provide for review and the possibility of release,” Marsha Levick, chief legal counsel at the Juvenile Law Center, said in a statement.
“The court has rightly returned discretion to the sentencer to make individualized determinations about each youth who stands before them, based on that youth’s particular qualities and degree of blameworthiness.”
The Alabama-based Equal Justice Initiative, which brought the two cases at hand before the Supreme Court, lauded the ruling as a “significant step forward.”
“The court took a significant step forward by recognizing the fundamental unfairness of mandatory death-in-prison sentences that don’t allow sentencers to consider the unique status of children and their potential for change,” EJI’s Bryan Stevenson told the Washington Post. “The court has recognized that children need additional attention and protection in the criminal justice system.”
Tagged chief justice john roberts, eighth amendment, equal justice initiative, evan miller cole cannon, jackson v. hobbs, justice elena kagan, juvenile justice, juvenile law center, kuntrell jackson laurie troup, miller v. alabama, SCOTUS, Supreme Court, supreme court bans mandatory life sentences for juveniles