Miller v. Alabama/Jackson v. Arkansas
In the two cases Miller v Alabama and Jackson V. Arkansas, two 14 year old juveniles were found guilty of murder and received life imprisonment sentences without parole. The Supreme Court in a landmark decision overturned the decision citing the decision to be unconstitutional, and prohibited mandatory life sentences for juvenile offenders without parole, in consideration of the juvenile’s potential for change (AP, 2017).
The case background involves Miller and Jackson who had committed and participated in acts of homicide. Miller, along with his friend had beaten another boy and set his trailer on fire, resulting into his death. Miller was charged initially as a juvenile but later shifted to an adult hearing, where he was found guilty of murder by arson. He was given a life sentence without parole. Jackson accompanied two other boys to commit a robbery at a video store in which one of his co-conspirators had carried a shotgun and fired at the store manager. Jackson was also charged with aggravated robbery and capital felony murder (Miller v. Alabama and Jackson v. Hobbs, 2012).
The Supreme Court of the United States, in a 5-4 vote in 2012 declared that sentencing juveniles to a life sentence without parole amounted to an unusual and cruel punishment and was unconstitutional. The Eighth Amendment’s prohibition was recalled by the majority of the jury that prohibits unusual and cruel punishments and grants the right for individuals to not be subject to excessive sanctions. The judicial principle behind is that an offender should be handed only a punishment that is graduated and proportionate to the offence (AP, 2017). The decision stated:
“In neither case did the sentencing authority have any discretion to impose a different punishment. Such a scheme prevents those meting out punishment from considering a juvenile’s `lessened culpability’ and greater capacity for change” (Miller Vs Alabama, 2012)
According to Justice Kagan, “It prevents taking into account the family and home environment that surrounds him – and from which he cannot usually extricate himself – no matter how brutal or dysfunctional” (Adam Liptak, 2012)
The Supreme court put into review a previous case law related to children’s criminal sentences. It previously held that capital punishment cannot be given to children on account of the Eighth Amendment, and neither can parole be denied to a juvenile who is given a life sentence, on account of a non-homicide offence. Those case lines also noted that a life sentence for juveniles without parole is comparable to a death penalty. Another line of Supreme Court cases required authorities to take into consideration the defendant’s characteristics and offence details before passing the death sentence (Miller v. Alabama and Jackson v. Hobbs, 2012). Based on the above case lines, the Court declared that juveniles must not be handed life sentences without parole as it is a violation of the Eighth Amendment. It was also acknowledged that children must be constitutionally regarded as different from adults due to an underdeveloped sense of responsibility and a lack of maturity that can lead to impulsivity, recklessness and heedless risk-taking.
The dissenting positions argued against the majority decision, as Judges Scalia, Roberts, Alito and Thomas said that the Eighth Amendment lays only a prohibition against unusual and cruel punishments, whereas a life without parole cannot reasonably be labelled as unusual since there are already 2500 prisoners that are serving their life sentences for homicide offences committed before they were 18, with many of them mandated statutorily. Furthermore, the courts precedents that require taking into account ‘evolving standards of decency’ and an “objective indicia of society’s standards” also concludes that the punishment may not be termed unusual. Judge Scalia and Thomas remarked that the decision is not consistent with how the unusual and cruel punishment clauses were understood, in the precedents the court relied upon, since they were only meant to be applicable on the methods of punishment that were adopted (Barnes, 2012). Judge Alito also remarked that the trend of Eighth Amendment precedent adopted by the court actually ignores indicia according to the legislatures of the majority of the states, when they decided to decrease juvenile offenders sentences for those who were 17 at the time of committing the offence and had a maturity level almost the same as an adult.
The decision by the Supreme court was considered a victory for neuroscience as in earlier cases such as Roper v. Simmons, 543 U.S. 551 (2005) and Graham v. Florida, 130 S. Ct. 2011 (2010), the American Psychological Association also supported the position that developmental psychology and neuroscience suggested that juveniles were not as culpable as adults, therefore their vulnerability, immaturity and changeability should be taken into account before handing them sentences (APA, 2012). But although psychologically, they may have a less sense of responsibility than adults, if the level of crime is same then they deserve a similar punishment. Because it is not always a question of science, but ultimately a moral and a legal question. Science alone should not drive a court decision, but only serve as a rhetorical leverage for judges when they write an opinion. I find myself agreeing more with the line of reasoning adopted by the dissenting judges, since the case has multiple implications. The rights of the victims family and social effects of the decision must also be taken into account before relying on ever evolving psychological research, especially when the constitutional clause could also be interpreted differently.
Adam Liptak, E. B. (2012, June 25). Justices Bar Mandatory Life Terms for Juveniles. Retrieved April 2, 2018, from New York Times: https://www.nytimes.com/2012/06/26/us/justices-bar-mandatory-life-sentences-for-juveniles.html?hp
AP. (2017, July 31). Miller v. Alabama and Jackson v. Hobbs. Retrieved April 2, 2018, from The Associated Press: https://www.ap.org/explore/locked-up-for-life/Miller-v-Alabama-and-Jackson-v-Hobbs
APA. (2012). Miller v. Alabama and Jackson v. Hobbs. Retrieved April 2, 2018, from american Pscyhological Association: http://www.apa.org/about/offices/ogc/amicus/miller-hobbs.aspx
Barnes, R. (2012, June 25). Supreme Court says states may not impose mandatory life sentences on juvenile murderers. Retrieved from The Washington Post: https://www.washingtonpost.com/politics/supreme-court-says-states-may-not-impose-mandatory-life-sentences-on-juvenile-murderers/2012/06/25/gJQAv1H21V_story.html?utm_term=.7200952e5db9
Miller v. Alabama and Jackson v. Hobbs, 567 U.S. —- (2012); 132 S. Ct. 2455 (Supreme Court of the United States June 25, 2012). Retrieved from http://www.supremecourt.gov/opinions/11pdf/10-9646g2i8.pdf
Miller Vs Alabama. (2012, March 20). Retrieved from Legal Information Institute: https://www.law.cornell.edu/supremecourt/text/10-9646