Miller v. Alabama

Whether a sentence of life imprisonment without the possibility of parole violates the Eight and Fourteenth Amendments when the defendant was fourteen years old at the time of the crime.

When Miller was fourteen-years-old, he robbed a man and beat him with a baseball bat. Miller then left the immobilized man on the floor of a trailer and set it on fire. The man died and Miller was convicted in state court of capital murder and sentenced to life in prison without the possibility of parole. Miller appealed, claiming the sentence violated his Eighth Amendment rights. The Alabama Court of Appeals affirmed the conviction, holding that Miller did not meet his burden of establishing that his sentence was cruel and unusual. In its analysis, the court of appeals determined that there was no national consensus against sentencing minors; evaluated the severity of the sentence in light of Miller’s individual culpability and the nature of the crime; considered the penological goals Miller’s sentence served, and determined that his sentence did not violate the Eighth Amendment. The Alabama Supreme Court denied Miller’s petition for a writ of certiorari.

On appeal to the United States Supreme Court, Miller argues that the mandatory sentencing scheme under which he was sentenced precludes consideration of his age or any other mitigating circumstances and is therefore in violation of both the Eighth and Fourteenth Amendments. Further, Miller argues that in Roper v. Simmons and Graham v. Florida, the Supreme Court recognized that age is a critical feature in determining a defendant’s culpability, and that by ignoring his age in sentencing the trial court violated the Constitution’s prohibition on cruel and unusual punishment.