## 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

1. 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.
2. 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.


Montgomery v. Louisiana, 577 U.S. 190 (2016)