SCOTUS Strikes Down Mandatory Life Without Parole Law For Juveniles

An important criminal law sentencing issue made national headlines this week as the U.S. Supreme Court issued a close, 5-4 ruling striking down one form of punishment for juveniles as unconstitutional. In Miller v. Alabama, the court held that mandatory life without parole sentences for juveniles was in violation of the U.S. Constitution’s 8th Amendment prohibition of cruel and unusual punishment. Importantly, this ruling does not mean that juveniles convicted of the harshest crimes can never be sentenced to life without parole. Instead, the ruling only strikes down laws which mandate such a sentence. The court decided that judges must be given the option of considering an individual’s age when finalizing the sentence.

This decision is similar to a string of cases decided by the court in recent years striking down harsh penalties for those who commit crimes before their 18th birthday. For example, in 2005 the court abolished the death penalty for juvenile criminals.

It remains unclear if the ruling will apply retroactively to those already convicted of mandatory life without parole for crimes committed as juveniles.

Did It Go Far Enough?
Two of the justices in majority–Justices Breyer and Sotomayor–wrote separately, noting that they would actually like the ruling to go even further. If they had their way the justices would prohibit all impositions of mandatory life in prison without parole for crimes where a defendant did not intend to kill or actually kill.

For example, one of the defendants in the Miller case was a 14-year old boy who robbed a video store with two teen friends. During the course of the robbery the boy was a “look out,” standing outside of the store while his two friends went inside. While inside, one of the friends shot and killed the store clerk. The boy himself did not shoot the clerk or have any intention of doing so. Yet, because of “felony-murder” laws in the state, he was treated as having killed the clerk. That triggered the mandatory life without parole sentence.

Justices Breyer and Sotomayor argued that all defendants, even adults, charged with murder in this way–without committing the act themselves–should not receive life without parole.

The Law in California
California has laws that allow these juveniles to be sentenced to life without parole, but they are not mandatory. Judges always have the flexibility to lower a sentence as a result of the defendant’s age. However, some state lawmakers are pushing for changes to the rules such that all life without parole sentences are prohibited. As reported this week in Mercury News, for example, State Senator Leland Yee has consistently pushed for legislation to get rid of the penalty. However, the measures have yet to advance in the statehouse.

In any event, those working closely on juvenile criminal issues applaud the common sense U.S. Supreme Court ruling, which ensure some fairness and individual analysis in all cases involving juveniles. .


If you or someone you know is facing criminal charges in our area, please contact the California criminal law attorney at the Johnson Criminal Law Group to discuss your case