Miller v. Alabama

Whether a sentence of life imprisonment without the possibility of parole is cruel and usual punishment under the Eighth Amendment when the offender was fourteen years old at the time of the criminal action.

Miller, a fourteen-year-old, beat a man with a baseball bat until the man could no longer get up from the floor of his trailer and then Miller set the trailer on fire. The victim died and Miller was convicted of capital murder and was sentenced to life without the possibility of parole.

The Alabama Court of Appeals affirmed Miller’s conviction. The court held that to find that Miller’s sentence violated the 8th amendment, Miller needed to show that 1) there is a national consensus against sentencing 14-year-olds who have been convicted of capital murder to life in prison without the possibility of parole or 2) that Miller’s crime falls into a category of crimes that are less culpable. The court noted that this is a heavy burden to meet and Miller was unable to meet this burden. The court, in considering the legitimacy of the penological goals that Miller’s sentence serves, concluded that the state has a legitimate penological goal to seek retribution for children who commit capital murder. Finally, the court held that Miller’s sentence did not violate his Constitutional right to individualized sentencing because the Supreme Court has held that only in cases involving a death sentence is individualized sentencing required by the Constitution.