RESPONDENT: State of Louisiana
LOCATION: Orleans Parish Criminal District Court
DOCKET NO.: 14-6381
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: Louisiana Supreme Court
CITATION: US ()
GRANTED: Dec 12, 2014
DECIDED: Feb 03, 2015
Facts of the case
In the 1980s, George Toca was arrested and sentenced to life in prison without the possibility of parole, probation, or suspension of his sentence for accidentally shooting his friend while the two of them committed a robbery. At the time of the robbery, George was 17 years old and was considered a juvenile. In 2012, the Supreme Court held in Miller v. Alabama that sentencing a juvenile to life in prison without the possibility of parole was a violation of the Eighth Amendment's protection against cruel and unusual punishment. In light of the Miller case, Toca applied for a Motion to Correct an Illegal Sentence, which the district court approved by holding that the Miller decision applied retroactively to cases like Toca's. The Supreme Court of Louisiana overturned that decision by denying Toca's motion and holding that the Miller rule does not apply retroactively because it is not a substantive rule, nor does it correct any substantive issues of fairness or accuracy in the criminal proceedings. The Supreme Court of Louisiana also held that the Miller rule is simply a new rule of criminal procedure and does not apply retroactively.
1. Does the rule in Miller apply retroactively to juveniles sentenced to life in prison without the possibility of parole?
2. Does the Supreme Court have jurisdiction where a state court has failed to find a Teague exception?