Miller v. Alabama Case Brief

Facts of the case

In July 2003, Evan Miller, along with Colby Smith, killed Cole Cannon by beating Cannon with a baseball bat and burning Cannon’s trailer while Cannon was inside. Miller was 14 years old at the time. In 2004, Miller was transferred from the Lawrence County Juvenile Court to Lawrence County Circuit Court to be tried as an adult for capital murder during the course of an arson. In 2006, a grand jury indicted Miller. At trial, the jury returned a verdict of guilty. The trial court sentenced Miller to a mandatory term of life imprisonment without the possibility of parole.Miller filed a post trial motion for a new trial, arguing that sentencing a 14-year-old to life without the possibility of parole constituted cruel and unusual punishment in violation of the Eighth Amendment. The trial court denied the motion. On appeal, the Alabama Court of Criminal Appeals affirmed the lower court’s decision. The Supreme Court of Alabama denied Miller’s petition for writ of certiorari.In the companion case, petitioner Kuntrell Jackson, along with Derrick Shields and Travis Booker, robbed a local movie store in Blytheville, Arkansas in November, 1999. The three boys were 14 years old at the time. While walking to the store, Jackson discovered that Shields was hiding a shotgun in his coat. During the robbery, Shields shot the store clerk and the three boys fled the scene. Jackson was tried and convicted of capital murder and aggravated robbery in July, 2003. The trial court sentenced Jackson to a mandatory term of life imprisonment without the possibility of parole.In January 2008, Jackson filed a petition seeking a writ of habeas corpus in circuit court. He argued that his sentence was unusual and excessive, violating his rights under the Eighth and Fourteenth Amendments. The circuit court dismissed the petition and Jackson appealed. The Supreme Court of Arkansas affirmed the lower court’s decision.

CONCLUSION

The Court held that mandatory life without parole for a juvenile precluded consideration of his chronological age and its hallmark features — among them, immaturity, impetuosity, and failure to appreciate risks and consequences. It prevented taking into account the family and home environment surrounding him — and from which he could not usually extricate himself — no matter how brutal or dysfunctional. It neglected the circumstances of the homicide offense, including the extent of his participation in the conduct and the way familial and peer pressures may have affected him. Indeed, it ignored that he might have been charged and convicted of a lesser offense if not for incompetencies associated with youth — for example, his inability to deal with police officers or prosecutors (including on a plea agreement) or his incapacity to assist his own attorneys. The Eighth Amendment forbade a sentencing scheme that mandated life in prison without possibility of parole for juvenile offenders. While there was, in some states, prosecutorial discretion in deciding whether to try a juvenile as an adult, those provisions were usually silent as to standards, protocols, or appropriate considerations.

  • Advocates: Bryan A. Stevenson for the petitioners John C. Neiman Jr. Solicitor General of Alabama, for the respondent Kent G. Holt for the respondent in the companion case
  • Petitioner: Evan Miller
  • Respondent: Alabama
  • DECIDED BY:Roberts Court
  • Location: –
Citation: 567 US _ (2012)
Granted: Nov 7, 2011
Argued: Mar 20, 2012
Decided: Jun 25, 2012
Miller v. Alabama Case Brief