Jackson v. Hobbs

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

Petitioner was convicted of murder and sentenced to life imprisonment without 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 the court lacked jurisdiction to sentence him to life imprisonment without the possibility of parole. The Arkansas Supreme Court affirmed and held that because Petitioner’s sentence conformed to Arkansas statutory requirements, his detention was 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.

On appeal, Petitioner argues that because children lack the physical and psychological development of an average adult, the court should use a different analysis than the court’s traditional “excessiveness” test in determining “cruel and unusual punishment.” Respondent argues, however, that there is no “societal consensus” against imprisoning 14-year-old convicted murderers to life in prison without the possibility of parole.