Facts
- In 1963, Henry Montgomery, age 17, shot and killed a Louisiana deputy sheriff.
- A jury convicted Montgomery of murder and sentenced him to death; the conviction was later annulled due to public prejudice.
- In 1969, Montgomery was retried, convicted, and—under Louisiana law—automatically sentenced to life imprisonment without parole based on the verdict form used.
- After Miller v. Alabama (2012) held mandatory life without parole for juvenile homicide offenders unconstitutional under the Eighth Amendment, Montgomery sought state collateral relief to correct his sentence.
- Louisiana courts denied relief on the ground that Miller did not apply retroactively to cases on state collateral review.
Issues
- Whether the U.S. Supreme Court has jurisdiction to review a state court’s collateral-review decision refusing to apply a federal constitutional rule retroactively.
- Whether Miller v. Alabama announced a substantive constitutional rule that must be applied retroactively on state collateral review.
Decision
- The Court held it had jurisdiction to review Louisiana’s refusal to apply Miller retroactively.
- The Court held Miller announced a substantive rule and therefore must apply retroactively on state collateral review.
- The Court reversed the Louisiana Supreme Court and remanded.
- The Court stated states need not resentence every affected prisoner and may remedy a Miller violation by extending parole eligibility to juvenile offenders.
Legal Principles
- Under the Teague v. Lane retroactivity framework, new substantive constitutional rules apply retroactively on collateral review.
- Substantive rules include rules that prohibit a category of punishment for a class of offenders because of their status or offense, placing the punishment beyond the state’s power to impose.
- Because Miller effectively forbids mandatory life without parole for juvenile homicide offenders (permitting it only for the rare juvenile whose crime reflects permanent incorrigibility), it is substantive rather than merely procedural.
- When a state continues to enforce a punishment barred by a substantive constitutional rule, the resulting sentence is unlawful, and state collateral courts must give the rule retroactive effect.
Conclusion
The Court required states to apply Miller retroactively in collateral proceedings because it announced a substantive Eighth Amendment limit on punishment for juveniles, and it permitted states to implement relief through resentencing or parole-eligibility mechanisms.