Supreme Court rules mandatory life sentences for juveniles unconstitutional

[JURIST] The US Supreme Court on Monday ruled 5-4 [opinion, PDF] in two combined cases that mandatory life sentences for juveniles violate the Eighth Amendment [text] prohibition against cruel and unusual punishment. In Miller v. Alabama and Jackson v. Hobbs [SCOTUSblog backgrounders], the court was asked to consider the life sentences of two 14-year-old boys who, after being convicted of murder, were sentenced to life in prison based on a statutory mandate. The sentencing judge had no authority to give the juveniles a lesser sentence. In her decision, Justice Elena Kagan concluded that the mandatory sentencing scheme was not an appropriate standard for juveniles:

Such mandatory penalties, by their nature, preclude a sentencer from taking account of an offender's age and the wealth of characteristics and circumstances attendant to it. Under these schemes, every juvenile will receive the same sentence as every other—the 17-year-old and the 14-year-old, the shooter and the accomplice, the child from a stable household and the child from a chaotic and abusive one. And still worse, each juvenile (including these two 14 year-olds) will receive the same sentence as the vast majority of adults committing similar homicide offenses—but really, ... a greater sentence than those adults will serve.
The court's decision did not address whether it is generally constitutional to sentence a juvenile to life in prison without a mandatory sentencing scheme. Chief Justice John Roberts, and Justices Clarence Thomas and Samuel Alito each entered dissenting opinions in the case, concluding that the court should defer to the judgment of the legislators who enacted the statutory mandates.

The court heard oral arguments [JURIST report] for the combined cases in March. One of the concerns advanced by the justices regarded the age limit upon which to base a ban against mandatory life sentences. In Miller, Justice Antonin Scalia asked, "What's the distinction between 14 and 15? ... How are we to know where to draw those lines?" Later, Miller's attorney called for 18 to be the minimum age needed to impose a life sentence, and pointed out that most of the jurisdictions that have considered the issue in a legislative context have adopted an age 18 minimum for mandatory life sentences. He offered that those jurisdictions that permitted the imposition of mandatory life-sentences did so through a regime that transferred juveniles to the adult criminal justice system where they are exposed to mandatory life sentences, not because of the express will of the people or their legislators to impose mandatory life sentences on juvenile offenders. He indicated that roughly 80 percent of life sentences imposed on juveniles were a result of mandatory sentencing regimes. The Supreme Court agreed to hear [JURIST report] the cases in November.

 

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