On June 25, 2012, the United States Supreme Court ruled 5-4 that it is unconstitutional to impose a mandatory life-without-parole sentence on someone who was under the age of 18 at the time of the crime. The Court struck down all statutes that require a child to be sentenced to die in prison. The ruling granted new sentencing hearings for Kuntrell Jackson and Evan Miller, petitioners in the two cases before the Court, both of whom were automatically sentenced to life in prison without parole for crimes they committed at the age of 14.*
The Court held that imposing mandatory life-without-parole sentences on children “contravenes Graham’s (and also Roper’s) foundational principle: that imposition of a State’s most severe penalties on juvenile offenders cannot proceed as though they were not children.” Therefore, regardless of the crime committed, child status matters.
Justice Kagan, writing for the majority, said that sentencing should include consideration of a child’s chronological age and its hallmark features, such as immaturity, impetuosity and failure to appreciate risks and consequences. It also should take into account the family and home environment — from which the youth cannot usually extricate himself, even if it is brutal or dysfunctional, as well as the youth’s role in the crime and potential to become rehabilitated.
The Court also was clear that discretionary life without parole sentences should be rare. Justice Kagan wrote, “Given all that we have said in Roper, Graham, and this decision about children’s diminished culpability, and heightened capacity for change, we think appropriate occasions for sentencing juveniles to this harshest possible penalty will be uncommon.” The ruling affects hundreds of individuals whose age and other mitigating factors were not taken into account at sentencing.
*Miller v. Alabama and Jackson v. Hobbs are companion cases that were argued separately but that shared one Supreme Court opinion.