The nation’s high court said a juvenile who commits murder could not be automatically sentenced to life in prison without the possibility of parole.
The Supreme Court held 5-4, in Miller v. Alabama, “that mandatory life without parole for those under the age of 18 at the time of their crimes violates the Eight Amendment’s prohibition on cruel and unusual punishments.”
The court affirmed that children are “constitutionally different from adults for purposes of sentencing.”
Children have less culpability and greater prospects for rehabilitation and therefore are less deserving of the most severe punishment. The majority’s decision was based “not only on common sense” but on science and social science.
The court, in a 5-4 decision, invalidated the sentences of two men who had committed murder at the age of 14 and were sentenced to life imprisonment without the possibility of parole.
In each case, state law mandated a sentence of life without the possibility of parole.
The sentencing courts could not consider the youth of the offenders or the nature of the crime.
In 2005, the Supreme Court held in Roper v. Simmons that it was unconstitutional to sentence juveniles to death.
In 2012, the court ruled in Graham v. Florida that juveniles, who do not commit murder, could not be sentenced to life without the possibility of parole. The court considered a juvenile’s “lessened culpability” compared to an adult who commits a similar crime and greater “capacity for change.” The court said the punishment of life without the possibility of parole was compared to the death penalty.
The Miller ruling said for a court to impose the death penalty, it must consider the characteristics of a defendant and the details of the crime. Similarly, before imposing a sentence of life without the possibility of parole on a child, a court must consider the child’s age and role in the crime.
The court relied on psychological and scientific studies used in the Graham decision, showing the difference between juvenile and adult minds, particularly in behavior control. The court also noted the susceptibility and vulnerability of children to criminal behavior by their peers.
The decision reiterated the reasoning used in Graham that “youth matters in determining the appropriateness of a lifetime of incarceration without the possibility of parole.”
The court’s decision requires that a juvenile receive individualized consideration when sentenced for murder.
The cases cited for this article are: Miller v. Alabama (No. 10-9646, June 25, 2012), Roper v. Simmons (543 U.S. 551), and Graham v. Florida (560 U.S.___).