Case Summary
In case number 10-9647, Jackson together with his two companions goes to a video store to conduct a robbery. The fourteen-year-old learns that one of his companions is armed ( Miller v. Alabama , 2012). He decides to remain outside the facility while his colleagues are on with the robbery for most of the time but ultimately decides to go in ( Miller v. Alabama , 2012). When he enters the facility, the colleague with the gun kills the store clerk. Jackson is charged with capital felony, aggravated robbery, and murder by the Arkansas Supreme Court and is convicted of both crimes ( Miller v. Alabama , 2012). Despite his appeal that the ruling is harsh and undeserving for a 14-year-old, his petition is dismissed, and the court ruling is retained ( Miller v. Alabama , 2012).
On the other hand, in case number 10-9646, Miller and his companion, after engaging in drinking and drug use beat his neighbor and set fire on the neighbor's trailer. The neighbor dies. Miller faces charges as a juvenile but is later transferred to a court of arson and charged as an adult ( Miller v. Alabama , 2012). The Alabama court of criminal appeals determined that the punishment rendered deserved and permissible under the eighth amendment given the gravity of the crime conducted ( Miller v. Alabama , 2012).
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Legal and procedural history
Following the hearing of their cases, Miller and Jackson made appeals for rehearing under different levels.
Miller made an application for a motion to a have a new trial. The Alabama criminal court of the appeal refused to grant such an opportunity, and the Supreme Court affirmed the court of appeal's decision. Miller's ground was that the court had violated the Eighth Amendment, which prohibited condemnation of a 14-year-old to a life sentence without the possibility of parole.
Jackson, on the other hand, applied for a state petition under habeas corpus principle, reasoning in a similar line that the court’s ruling violated the eighth amendment. The Arkansas circuit court and the court’s ruling affirmed by the Supreme Court dismissed his application. The United States Supreme Court, in both cases, granted certiorari.
Facts
Miller
Miller and his accomplice, in 2003 while at the age of 14, hit Cole cannon with a baseball bat and to cover the traces of their crime did set Cannon's trailer on fire while he was lying helpless inside, which led to Cannon's death. Miller had a history of mistreatment from his stepfather, a drug-addicted mother, and a personal record of engaging in alcohol and drugs besides having mental disturbances. Miller was then charged with two crimes: arson and murder and is sentenced to mandatory life imprisonment without parole.
Jackson
Jackson and his two accomplices, all 14-year-olds, in 1999 organize and conduct a robbery at a movie store. One of his friends carries with him a short gun that he uses to shoot at the movie store clerk. Jackson is outside the store for most of the time that the two companions are inside the store but upon entering the store, the murder occurs. Similarly, Jackson is charged with mandatory life imprisonment without parole having been found guilty of a capital felony by the court.
Issue and Holding
Does the subjection of an under 18-year-old to mandatory life imprisonment without the privilege of parole do harm to the eighth amendment? Yes
Supreme Court’s Judgment
The Supreme Court administered certiorari in both cases whereby a higher court was granted the opportunity of revising a case ruling by the lower courts. The Supreme Court found that the two courts, Alabama and Arkansas, had violated the eighth amendment.
Reasoning
The Supreme Court's reasoning was based on two prior cases and the essence of the eighth amendment. The eighth amendment prohibited administration of overburdening punishment to juveniles such as life sentencing without parole or a death sentence; these punishments are viewed, under that age bracket, as unusual and severe. In the cases, Roper v. Simmons and Graham v. Florida , the court hearings had ruled against the death penalty and life sentence without parole respectively, which were applied by the Supreme Court.
Dissenting Opinions
Roberts
He termed a mandatory life sentencing without parole as not being “unusual” when several states courts agreed that it could be applied to several juvenile cases meeting the criteria. He argued further that neither the constitution nor preceding court cases disallowed the application of the ruling for homicide cases.
Thomas
He criticized the use of the roper and Graham cases citing that the ruling had deviated from an original understanding of the eighth amendment.
Alito
He condemned the Supreme Court’s decision as taking away the prerogative of state courts in deciding cases.
Analysis
Significance
The law prohibits the sentencing of a person to a sentence that is overbearing based on the nature of the crime and the condition of the petitioner such as age or any form of disability such as being mentally retarded. Therefore, the case of Miller v. Alabama , involving both juveniles one sentenced to life imprisonment without parole for committing non-homicide crimes and another for engaging in homicide crime but both being below the age of 18 is considered as a violation of the eighth amendment ( Caldwell, 2015 ). Again, the cases involved the transfer of the defendants to other courts without carefully reviewing the defendants past. The cases can be viewed as being procedural and substantive. They are substantive in the sense that they are revolutionary and introducing new concepts in court ruling and are procedural given that they require a review of the petitioner’s past before arranging for any transfer ( Caldwell, 2015 ).
The Eighth Amendment protects juveniles from receiving the same treatment as adults given their unformed traits as compared to adults who have a fixed trait and a resolved intent to commit a crime. I agree with the Supreme Court's decision in that it followed the law in reversing the state's decisions in both cases seeing that a violation of the law will lead to subsequent violations and that the rule of law will be meaningless given the court's habit of referring to previous rulings in making major decisions.
References
Caldwell, B. (2015). Miller v. Alabama as a Watershed Procedural Rule: The Case for Retroactivity. Harv. L & Pol'y Rev. Online S1, 10.
Miller v. Alabama , 132 S. Ct. 2455, 567 U.S. 460, 183 L. Ed. 2d 407 (2012).
