Alabama argues that these statutes provide strong evidence of a societal judgment that some crimes are so repugnant that life without parole is an appropriate sentence, even when the defendant is only 14 years old. The parties’ debate centers on differing interpretations of the Supreme Court cases of Roper v. Simmons and Graham v. Florida, the former of which held that minors cannot be sentenced to the death penalty and the latter of which held that minors cannot be sentenced to life in prison without parole for non-homicide offenses. The United States Supreme Court on June 25, 2012, issued an historic ruling in Miller v. Alabama and its companion case, Jackson v. Hobbs, holding that mandatory life-without-parole sentences for all children 17 or younger convicted of homicide are unconstitutional. As we noted the last time we considered life-without-parole sentences imposed on juveniles, "[t]he concept … Miller v. Alabama, 567 U.S. 460 (2012), was a United States Supreme Court case in which the Court held that mandatory sentences of life without the possibility of parole are unconstitutional for juvenile offenders. In contrast, Alabama argues that sentencing a 14-year-old to life without parole serves justifiable penological aims. [Facts] The two 14yearold offenders in these cases were convicted of murder and sentenced to life imprisonment without the possibility of parole. Miller filed a post trial motion for a new trial, arguing that sentencing a 14-year-old to life without the possibility of parole constituted cruel and unusual punishment in violation of the Eighth Amendment. Petitioner Evan Miller draws a direct comparison between the adolescents in Roper and Graham and himself. This raises wide-reaching moral and doctrinal questions about where American law should draw the line in sentencing a minor to lifetime imprisonment. 122 Commerce Street Montgomery, AL 36104 A group of former Juvenile Court Judges argue that Miller’s sentence of life without parole must be reconsidered given the unique ability of youth to rehabilitate following a criminal act. Harmelin challenged this, saying that it was cruel and unusual in violation of the Eighth Amendment. The Supreme Court of Alabama denied Miller's petition for writ of certiorari. Miller emphasizes the particularly adverse conditions of his own upbringing, noting that he was raised in an abusive household and lacked positive role models growing up. Respondent Alabama responds by distinguishing the facts of both Roper and Graham; according to Alabama, this case is not simply “Graham and Roper redux.” Rather, Alabama argues, this case involves a more lenient sentence than the one at issue in Roper and a more serious crime than the one at issue in Graham. According to Alabama, this legislative evidence of sentencing statutes is the only kind of law relevant to the analysis. Alabama responds by arguing that, in relative terms, this seemingly small number of life sentences does not indicate a rarely accepted practice because very few juveniles commit homicidal crimes in the first place. Cannon fell unconscious as a result of smoking and drinking, at which point Miller took $300 and Cannon’s driver’s license from Cannon’s wallet. Miller v. Alabama (2012) In Miller v. Alabama (2012), 5 the U.S. Supreme Court considered two cases of 14-year-old juveniles who had been convicted of murder. Does such a sentence violate the Eighth and Fourteenth Amendments when it is imposed upon a 14-year-old child as a result of a mandatory sentencing scheme that categorically precludes consideration of the offender’s young age or any other mitigating circumstances? Does Sentencing a Minor to Life Without Parole Conform to National Standards of Decency? Thus, according to Alabama, this case occupies a gap in Eighth Amendment doctrine that neither case controls. According to Miller, this consensus reflects what “any parent knows” about adolescents’ lack of emotional development. According to Miller, he fits squarely into the category of individuals the Court was trying to protect in Roper and Graham, and a sentence that condemns him to life in prison directly contravenes the Court’s holding in those cases. Investigators then performed an additional investigation of Cannon’s trailer and an additional full autopsy of Cannon. The Supreme Court of the United States granted certiorari on November 7, 2011, and scheduled Miller’s case to be argued in tandem with Jackson v. Hobbs. Miller was initially charged as a juvenile, but his case was removed to adult court, where he was charged with murder in the course of arson. The Alabama Court of Criminal Appeals affirmed, holding that Miller's sentence was not overly harsh when compared to his crime, and that its mandatory nature was permissible under the Eighth Amendment. The parties chiefly disagree over whether sentencing a 14-year-old to life in prison without parole violates the Eighth Amendment. The decision follows the Court’s earlier rulings in Roper v. Simmons (2005) and Graham v. Florida (2010), which acknowledge the diminished culpability of children. Specifically, Alabama cites to a study that suggests that a tendency towards violence as an adolescent will tend to persist into adulthood. Miller points primarily to three sources as support for his argument: psychological studies of adolescent behavior, legislative history distinguishing adolescents from adults, and actual sentencing practices in the courts. New York Times, Adam Liptak: Justices Will Hear 2 Cases of Life Sentences for Youths (Nov. 7, 2011). A jury found Miller guilty, and the trial court imposed a statutorily mandated punishment of life without parole. The judges argue that sentencing juvenile offenders to a term of years, rather than to life without parole, allows society to reassess a juvenile’s attempts at rehabilitation in coming years. The National District Attorneys Association adds that sentencing juveniles to life without parole is an appropriate punishment for juveniles that commit only the most horrendous crimes, like Miller. Alabama, like Miller, points to a wide variety of sources as evidence for this claim, including legislative history, sentencing practices, and scientific studies of adolescent psychology. The judges further claim that sentencing a youth to life without parole actually provides disincentives to the youth to attempt to reform both because of an obvious lack of hope and because those sentenced to life without parole often have limited access to prison vocational and self-help programs. Lastly, to directly refute Miller’s argument, Alabama contends that there is no research to support the argument that a 14-year-old has a lesser capacity for exercising sound judgment then an older adolescent criminal. As Miller put the wallet back in Cannon’s pocket, Cannon regained consciousness and attacked Miller. Miller v. Alabama Linked with: Jackson v. Hobbs Docket No. After the Circuit Court’s denial of the motion, Miller appealed to the Alabama Court of Criminal Appeals, challenging both the constitutionality of sentencing a 14-year-old to life without parole and the mandatory imposition of a life-without-parole sentence on a 14-year-old. Petitioner Evan Miller argues that such a sentence is repugnant to these standards. Held: The Eighth Amendment forbids a sentencing scheme that mandates life in prison without possibility of parole for juvenile homicide offenders. While Cannon was there, Miller and his co-defendant, Colby Smith, went to Cannon’s trailer in search of drugs. Miller points to the Supreme Court cases Roper v. Simmons and Graham v. Florida, which held that a minor cannot be sentenced to death and that a minor cannot be imprisoned for life for a non-homicidal crime, respectively, as evidence that his conviction contravenes nationally held standards of decency. The Supreme Court upheld Harmelin’s sentence. Second, Miller cites legislative history that distinguishes between adolescents and adults as evidence of a “broad consensus” that adolescents are generally different from adults. The Christian Post, Brendan Giusti: Supreme Court Ruling on Whether Life Sentences for Juveniles are Constitutional (March 2, 2012). See Miller v. State, 63 So.3d 676, 682–83 (Ala. Crim. In particular, the APA argues that youths are inherently less culpable than adults based on differences in neurological development. Whether sentencing a 14-year-old to life in prison without parole is cruel and unusual punishment? Kuntrell Jackson and Evan Miller, sentenced to life in prison without parole at 14, are now entitled to new sentencing hearings. The trial court denied the motion. The second full autopsy affirmed that Cannon’s death was a result of smoke inhalation, but added that Cannon’s death was also due to “multiple blunt force injuries and ethanol intoxication.”. Finally, Alabama points out that no juvenile receives a truly mandatory sentence because courts may always conduct a case-by-case review to determine whether a sentence violates the Eighth Amendment, regardless of the statutory minimum sentence.