Miller v. Alabama

A mandatory life sentence without the possibility of parole for juvenile homicide offenders violates the Eighth Amendment’s prohibition on cruel and unusual punishment.

This case was consolidated with Jackson v. Hobbs.

At age fourteen, Petitioner robbed a man and beat him with a baseball bat. Petitioner then left the immobilized man on the floor of a trailer and set fire to it. The man died and Petitioner was convicted of capital murder and sentenced to life without the possibility of parole. Petitioner appealed, claiming the sentence violated his Eighth Amendment rights. The state court of appeals affirmed the conviction, holding that Petitioner failed to 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 the sentence Petitioner received despite his age. Further, the court evaluated the severity of the sentence in light of Petitioner’s individual culpability and the nature of the crime, considering the penological goals served, and determined that the sentence did not violate the Eighth Amendment. The Alabama Supreme Court denied Petitioner’s petition for a writ of certiorari. The U.S. Supreme Court granted certiorari and combined the case with Jackson v. Hobbs (10-9647).

The Supreme Court reversed the state courts' judgments, holding that the mandatory sentencing schemes in both cases violated the Eighth Amendment. Finding that a requirement of lifetime incarceration without the possibility of parole for children convicted of homicide did not take into account the principle of proportionality, the Court held that in cases involving juveniles, the mitigating qualities of youth must be examined on a case-by-case basis. Further, the Court held that a judge or jury must be given the opportunity to consider a juvenile’s age, age-related characteristics, and the nature of the crime before imposition of such a sentence.