Jackson v. Hobbs

Whether sentencing a fourteen year old to life imprisonment without possibility of parole after being convicted of aggravated murder constitutes cruel and unusual punishment in violation of the Eighth Amendment.

Petitioner was convicted of murder and sentenced to life imprisonment without the possibility of parole. At the time of the murder, Petitioner was fourteen. After exhausting his immediate remedies, Petitioner filed a habeas corpus petition in circuit court. The court granted the State’s motion to dismiss because the court found that Petitioner failed to demonstrate his commitment was facially invalid or that court lacked jurisdiction to sentence him to life imprisonment without possibility of parole. The Arkansas Supreme Court affirmed and held that because Petitioner’s sentence conformed to Arkansas statutory requirements, his detention is not illegal. Further, the Arkansas Supreme Court held that a sentence of life imprisonment without parole does not violate the Eighth Amendment’s prohibition against cruel or unusual punishment when that sentence is within statutory bounds.

In Graham v. Florida, the Supreme Court recognized that cruel and unusual punishment attaches to juvenile defendants convicted of non-homicide crimes sentenced with life imprisonment without the possibility of parole. The Supreme Court granted certiorari to answer the question of whether a sentence of life imprisonment without the possibility of parole constitutes cruel and unusual punishment when the offender is a juvenile.