The Supreme Court reviewed the constitutionality of mandatory life sentences without parole enforced upon persons aged fourteen and younger found guilty of homicide. The court declared unconstitutional a compulsory sentence of life without parole for children. The states have been barred from routinely imposing sentences based on the crime committed. There is a requirement for individual consideration of the child life circumstance or the defendant status as a child. The court rejected the definite ban on life sentences without parole.
This is because in some cases the instances may be uncommon, but jurors can find irreparably corrupted children. The Supreme Court declined to decide the subject whether there is age below which children with life sentences without parole is unconstitutional.
Background of the case
The judgment of the court is mainly based on consolidation of two cases. In Jackson vs. Hobbs, Jackson was at the age of fourteen when he and other two youth went to a store in Arkansas planning to steal from it.
In this case, Jackson got charged as an adult and given a life term with no parole. In Miller v. Alabama, Miller was a fourteen year of age. Jackson and another boy set fire to a trailer where they had purchased drugs. Miller was convicted of murder and given a mandatory life sentence with no parole.
The decision was reversed by the Supreme Court. The review of the above cases was approved by the Supreme Court presenting the subject of constitutionality of a life sentence without parole for fourteen year olds who committed murder crimes. The two cases follow two previous cases before the Supreme Court. In the case of Roper v. Simmons, it was held that imposition of death penalty on defendants below the age of eighteen violated the eighth amendment. In the case of Graham v Florida, it was held sentencing defendants below the age of eighteen to life without parole violated the eighth amendment. It was held juveniles are less liable in light of changeability, vulnerability and immaturity.
Facts of the case
In each of the cases above, a fourteen year old was found guilty of murder and sentenced to a mandatory life imprisonment with no parole. In the case of Jackson, the petitioner had accompanied two other boys went to a video store to commit robbery. Jackson learned that one of the boys was having a shot gun. He was on the lookout, once he entered the store one of the boys shot the store clerk. Therefore, Jackson was charged by Arkansas as an adult with aggravated robbery and capital felony murder. He was convicted by the jury of both crimes.
A statutory sentence of life imprisonment was issued by the court with no parole. Jackson argued life imprisonment without parole for a fourteen year old violated the eighth amendment. In Miller case, after an evening of drug use and drinking the petitioner and a friend beat Millers neighbor and set fire to his trailer. The neighbor died in the process. At first, Miller was charged as a juvenile. The case was removed and moved to an adult court where he was charged with murder in course of arson. Miller was found guilty by the jury and a statutory life sentence without parole was imposed. The court of criminal appeal of Alabama stated that Millers sentence was not harsh compared to his crime. The mandatory nature was allowed under the eighth amendment.
The Supreme Court held that the eighth amendment outlaw sentencing system that direct life imprisonment with no parole for juvenile murder offender. The eighth amendment prohibits unusual and cruel punishment and provides assurance of individual right not to be put under extreme sanctions. In Roper v. Simons, it was established that the right stems from perception of justice, therefore punishment should be proportionate to the offence and the offender. There were two precedents that reflected on fair punishment.
There was one that adopted definite ban on sentencing system based on differences in severity of penalty and culpability of the offenders. That is why in Roper v. Simons, capital punishment for children was prohibited by the eighth amendment. In Graham v. Florida the eighth amendment also prohibited life sentence without parole for juvenile found guilty of non-homicide cases. This case further associated life sentence without parole for juvenile to death sentence. This suggested the second line of precedent that the court requires sentencing system to consider the details of the offence and characteristics of the defendant before sentencing him or her to death.
The two line of precedents guide the court to conclude that life sentence without parole for juveniles in fringeon theeighthamendment. The court decision was influenced by Graham and Roper cases that established for sentencing reasons children are different from adults under the constitution. Children lack maturity and have no developed sense of responsibility. This leads them to be impulsive and reckless. In Roper it was held children are exposed to outside pressure and negative influences from friends. Therefore, they have less control of their environment because the child’s nature is not2 well informed. Graham and Roper emphasized distinguishing traits of children weakening justification for inflicting harsh sentences to juveniles even when they commit outrageous crimes.
The court held in 5-4 majority that the eighth amendment forbids unusual and cruel punishment. Justice Kagan reversed Alabama and Arkansas Supreme court decisions. It was held under the constitutionally children are different from adults when it comes to sentencing. Justice Breyer had a concurring opinion arguing there is need for further determination if the offender intended to kill or killed the victim during the robbery. Justice Sotomayor supported the argument. However, Justice Roberts had a dissenting opinion. He argued that the court duty is to apply the law accordingly and not answer questions of social policy and morality. He argued the majority did not prove the punishment to be unusual. In his opinion, he did not find the punishment infringing on the eighth amendment. The dissent was joined by Justices Antonin Scalia, Samuel A, and Clarence Thomas.
My Opinion of the Case
I personally think the ruling by the Supreme Court on Miller v. Alabama is a welcome decision. I concur with Justice Kagan that mandatory life imprisonment for juvenile is like a sentence children to die in prison. Mandatory life sentence also infringes on the eighth amendment. It is true youths lack maturity and have no sense of responsibility. They are exposed to outside pressure and negative influences from friends and therefore their reasoning is not the same as adults. In wake of my support for Miller v. Alabama decision, I am sensitive to family victims who want retribution. However, I must reiterate that sentencing juveniles for life is not the way3 to go. There is need to think about this juveniles who have been given life without parole as our children.
They need to be given an opportunity to come out and prove themselves as better people in society. Friend and families of victims would ask me why they deserve a second chance. It is true they may be mourning but no matter how painful the mourning can be, that cannot change the reality that children are different from adults in society. Children have a great potential for growth, understanding and change. Our sentencing system should not be characterized with vengeance. There may be a need recognize the potential for change. The opportunity should be given to juveniles to experience joy, life, and find meaning. The ban on mandatory life sentence without parole will ensure juveniles become educated, be creative and impact on the society positively.