Retroactive Application of Miller v. Alabama to Eliminate Life Sentences Imposed on Juveniles

In 2012, the Supreme Court granted certiorari to hear Miller v. Alabama, which involved two 14-year-old boys who were convicted of murder during an attempted robbery. The state court allowed the juveniles to be tried as adults. As a result, at 14-years-old, they were sentenced to life imprisonment with no chance of parole due to mandatory sentencing guidelines, which did not allow the judge to consider any factors related to the juvenile’s life. In evaluating the state’s decision, the Supreme Court ruled that life without parole for juveniles violated the Eighth Amendment, which prohibits cruel and unusual punishment, when mitigating factors are not considered in the sentencing. The judge writing for the majority stated:

A Shred of Light into the District of Columbia’s Juvenile Justice System

The H. Carl Moultrie Courthouse, Superior Court of the District of Columbia

“The reformers who championed the establishment of juvenile courts in the United States envisioned a system in which youthful law violators would receive treatment and other forms of rehabilitation and thereby become productive members of society without forever being tarnished by criminal records as a result of youthful indiscretions.”[1]  This idea has unfortunately largely remained in the abstract; instead, many juvenile offenders face high recidivism rates throughout the United States.  Specifically, “an average of fifty-five percent of youth released from state custody in the United States are rearrested within a year, and an average of twenty-five percent are re-incarcerated in adult or juvenile custody within the same period.”