## Facts

- The Court consolidated two cases involving 14-year-old offenders convicted of homicide and sentenced under statutes requiring life imprisonment without parole (LWOP).
- In Arkansas, Kuntrell Jackson joined two other youths in a plan to rob a video store; a confederate shot and killed the clerk during the robbery, and Jackson was convicted as an adult of capital felony murder and aggravated robbery.
- Arkansas law required LWOP upon Jackson’s conviction; state courts denied habeas relief and upheld the sentence.
- In Alabama, Evan Miller and a friend beat a neighbor after drinking and drug use and set fire to the neighbor’s trailer, causing the neighbor’s death.
- Miller’s case was transferred from juvenile to adult court; he was convicted of murder in the course of arson.
- Alabama law required LWOP upon Miller’s conviction; state appellate courts affirmed the sentence and further review was denied.

## Issues

1. Whether the Eighth Amendment prohibits a sentencing scheme that mandates life without parole for juvenile homicide offenders without allowing consideration of youth and other mitigating circumstances.
2. Whether requiring LWOP for juveniles convicted of homicide violates the Eighth Amendment’s proportionality limits when imposed without individualized sentencing.

## Decision

- The Court reversed and held that the Eighth Amendment forbids mandatory LWOP for offenders who were under 18 when they committed homicide.
- The Court ruled that a sentencer must have discretion to consider youth and its characteristics before imposing LWOP on a juvenile.
- The Court did not categorically bar juvenile LWOP for homicide; it barred only mandatory schemes that eliminate individualized consideration.
- Justice Kagan authored the 5–4 majority opinion.

## Legal Principles

- The Eighth Amendment’s proportionality requirement requires punishment to account for both the offender and the offense, including diminished culpability associated with youth.
- Juveniles are constitutionally different from adults for sentencing because of immaturity, susceptibility to external pressures, and greater potential for change.
- When the harshest penalties are at stake, sentencing must permit individualized consideration of mitigating factors; mandatory statutes that require LWOP for juveniles prevent such consideration and are unconstitutional.
- Prosecutorial charging choices or transfer-to-adult-court procedures do not substitute for individualized sentencing at the punishment stage.

## Conclusion

Mandatory life-without-parole sentencing for juvenile homicide offenders violates the Eighth Amendment because it requires the sentencer to impose the harshest prison sentence without considering the offender’s youth and mitigating circumstances; discretionary, individualized sentencing is constitutionally required, though juvenile LWOP for homicide remains permissible in rare cases.


Miller v. Alabama, 567 U.S. 460 (2012)