ACLU Amicus Brief
Daniel S. Korobkin
Michael J. Steinberg
Kary L. Moss
Brandon Buskey
Ezekiel Edwards
SimpleOriginal

Summary

Miller's holding, whether deemed a substantive rule establishing establish rights and duties or a watershed rule ensuring fundamental fairness, should apply retroactively, thus altering legal consequences for impactful decisions.

2014 | State Juristiction

ACLU Amicus Brief

Keywords Miller; retroactive relief; resentencing; mandatory JLWOP; mandatory juvenile life without parole; mitigating facts; substantive rule; Teague; procedural rule; youth; individualized capital sentencing doctrine; Eighth Amendment

In Miller v Alabama, 567 US ; 132 S Ct 2455; 183 L Ed 2d 407 (2012), the UnitedStates Supreme Court held that "the Eighth Amendment forbids a sentencing scheme that mandates life in prison without possibility of parole for juvenile offenders." Id , 132 S Ct at 2469. Relying "not only on common sense—on what 'any parent knows'—but on science and social science as well," the Court recognized that "children are constitutionally different from adults for purposes of sentencing." Id. at 2464. Children are less culpable than adults, and theyare more capable of rehabilitation as they mature. Id. "By making youth (and all that accompanies it) irrelevant to imposition of that harshest prison sentence," the Court held that automatically sentencing youth to life imprisonment without parole "poses too great a risk of disproportionate punishment." Id. at 2469.

Miller unquestionably invalidates Michigan's sentencing scheme for juveniles, which mandates a life sentence for all first-degree murder convictions, makes prisoners serving such sentences ineligible for parole, and treats juveniles the same as adults. MCL 750.316(1), 769.1(1)(g), 791.234(6)(a). Raymond Carp, the defendant in this case, was convicted and sentenced under Michigan's unconstitutional scheme for an offense he committed when he wasonly 15 years old. He is serving a mandatory sentence of life in prison that carries no possibility of parole—precisely the type of punishment that Miller ruled unconstitutional.

Yet in its decision below, the Court of Appeals denied Carp any relief. Carp's conviction became final before Miller, and the Court of Appeals ruled that Miller applies only to judgments not yet final at the time it was decided. Under this rationale, a mere accident of timing would dictate that the vast majority of children with a mandatory life-without-parole sentence must continue to suffer this unconstitutional punishment for the rest of their lives. This includes children as young as 14 at the time of the offense, see People v Bentley, unpublished opinion per curiam of the Court of Appeals, issued April 11, 2000 (Docket No. 214170), as well as children who did not actually commit a homicide but were convicted of felony murder and/or under an aiding-and-abetting theory, see People v Maxey, unpublished opinion per curiam of the Court of Appeals, issued May 6, 2010 (Docket No. 289023) (Shapiro, J., concurring). In Michigan, there are over 360 prisoners serving mandatory life-without-parole sentences for offenses committed before the age of 18—a punishment the Supreme Court has described as "akin to the death penalty." Miller, 132 S Ct at 2466. The question for this Court is whether nearly all of these individuals must die in prison serving an unconstitutional sentence, forever denied "some meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation." See id. at 2469.

The answer is no. Under both federal- and state-law retroactivity principles, Miller applies to all juveniles who were given mandatory sentences of life in prison without parole. As a matter of federal law, the Supreme Court's decision in Teague v Lane, 489 US 288; 109 S Ct 1060; 103 L Ed 2d 334 (1989), requires that new constitutional rules be applied retroactively to cases on collateral review if they are "substantive" or if they are "watershed" rules of criminalprocedure. Miller is a "substantive" rule because 1) it categorically places juveniles as a class beyond the power of the state to punish with sentences of mandatory life imprisonment without parole, thereby requiring states to expand the range of possible sentencing outcomes forjuveniles; 2) it requires sentencing courts to consider the mitigating fact of youth before they may validly condemn a child to die in prison, thereby narrowing the factual circumstances under which juveniles may receive that sentence; and 3) it does not regulate the procedures that state courts must use in considering youth during sentencing. Alternatively, even if viewed as "procedural" rather than substantive, Miller must be applied retroactively under Teague as a watershed rule because the requirement of individualized sentencing is one without which juveniles stand too great a risk of being disproportionately sentenced. Lastly, irrespective of federal law, this Court should also give Miller retroactive effect as a matter of state law under People v Maxson, 482 Mich 385; 759 NW2d 817 (2008).

To deny Miller retroactive effect would permit the dark irony that those who havesuffered the longest under Michigan's unconstitutional sentencing scheme have the least hope for relief. It would deny hundreds of youth any possibility of release from an irrevocable sentence the Supreme Court has declared should be "uncommon" and "rare." Miller, 132 S Ct at 2469.

Summary

Introduction

In Miller v. Alabama (2012), the United States Supreme Court declared that mandatory life imprisonment without parole for juvenile offenders violates the Eighth Amendment's prohibition against cruel and unusual punishment. The Court recognized the inherent differences between juveniles and adults, emphasizing their diminished culpability and greater capacity for rehabilitation.

Michigan's Unconstitutional Sentencing Scheme

Michigan's sentencing scheme, which mandated life imprisonment without parole for all first-degree murder convictions, regardless of the offender's age, was rendered unconstitutional by Miller. This scheme failed to consider the mitigating factor of youth and posed an excessive risk of disproportionate punishment.

Retroactivity of Miller

Under federal law, the retroactivity of new constitutional rules is determined by the Teague v. Lane (1989) test. Miller qualifies as a "substantive" rule because it:

  • Categorically exempts juveniles from mandatory life without parole sentences.

  • Mandates individualized sentencing that considers the mitigating factor of youth.

  • Does not prescribe specific sentencing procedures.

Alternatively, Miller can be considered a "watershed" rule of criminal procedure, warranting retroactive application due to the fundamental importance of individualized sentencing in mitigating the risk of disproportionate punishment for juveniles.

Furthermore, under Michigan state law, Miller should be applied retroactively as established in People v. Maxson (2008).

Conclusion

Denying retroactive effect to Miller would perpetuate the injustice of Michigan's unconstitutional sentencing scheme, leaving hundreds of juvenile offenders to languish in prison without any prospect of release. The principles of both federal and state law mandate the retroactive application of Miller to all juveniles sentenced to life without parole, ensuring that they receive the opportunity for a meaningful review of their sentences based on their demonstrated maturity and rehabilitation.

Summary

In the landmark case of Miller v Alabama, the United States Supreme Court ruled that it is unconstitutional to sentence juvenile offenders to life in prison without the possibility of parole. The Court recognized that children are different from adults in several important ways:

  • Less Culpable: Children are less mature and have a diminished capacity for understanding the consequences of their actions.

  • More Capable of Rehabilitation: As children grow and mature, they are more likely to change and become productive members of society.

The Court held that sentencing juveniles to life without parole "poses too great a risk of disproportionate punishment."

Impact on Michigan's Sentencing Scheme

Michigan's sentencing laws for juveniles were found to be unconstitutional under Miller. The state had previously mandated life sentences for all first-degree murder convictions, regardless of the offender's age. This meant that even children as young as 14 could be sentenced to die in prison.

Retroactivity of Miller

The question arose as to whether Miller should apply to juveniles who had already been sentenced to life without parole before the ruling. The Court of Appeals initially denied relief to these individuals, arguing that Miller only applied to cases that were not yet final.

However, the author of the article argues that Miller should be applied retroactively to all juveniles sentenced to life without parole, regardless of when their conviction became final. This is because:

  • Substantive Rule: Miller prohibits a specific type of punishment for juveniles, making it a substantive rule.

  • Watershed Rule: The requirement for individualized sentencing is essential to prevent disproportionate punishment of juveniles.

  • State Law: Michigan courts have the authority to apply Miller retroactively under state law.

The author concludes that denying Miller retroactive effect would be a grave injustice, leaving hundreds of juveniles to die in prison for an unconstitutional sentence.

Summary

In a big decision, the Supreme Court said that it's wrong to automatically sentence kids to life in prison without the chance of getting out. They said that kids are different from adults because:

  • They're not as responsible for their actions.

  • They can change and become better people as they get older.

Michigan's Problem

Michigan had a law that said all kids who committed first-degree murder had to get life in prison without parole. That's the same punishment as adults. But the Supreme Court said that's not fair to kids.

One kid named Raymond Carp was only 15 when he was sentenced to life without parole. He's stuck in prison forever, even though the Supreme Court said that's wrong.

Should Raymond and Others Like Him Get a Second Chance?

The question is: Should all the kids in Michigan who got life without parole get a chance to get out of prison?

The answer is: Yes!

The Supreme Court said that kids deserve a chance to show that they've changed and become responsible adults. It's not fair to lock them up forever for something they did when they were young.

Hundreds of kids in Michigan are serving life without parole. They deserve a chance to prove that they're not the same people they were when they were kids. They deserve a chance at a future.

Summary

In a big court case called Miller v Alabama, the highest court in the United States said that it's not fair to sentence kids to life in prison without any chance of getting out.

Why Kids Are Different

The court said that kids are different from adults because:

  • They don't always understand the consequences of their actions.

  • They can change and become better people as they grow up.

Michigan's Old Law

In Michigan, there was a law that said if a kid was found guilty of a serious crime, they had to be sentenced to life in prison without any chance of getting out. This law didn't matter how old the kid was or what they had done.

The Problem with Michigan's Law

The court said that Michigan's law was unfair because it didn't give kids a chance to show that they had changed and deserved a second chance. The court said that sentencing kids to life in prison without any hope was too harsh.

What Happens Now?

Because of the court's decision, Michigan's law is no longer allowed. Kids who were sentenced to life in prison under the old law should have a chance to get out if they can prove they have changed and become better people.

There are many kids in Michigan who are still in prison under the old law. They deserve a chance to show that they have changed and should be given a second chance.

Footnotes and Citation

Cite

Brief of the American Civil Liberties Union and the American Civil Liberties Union of Michigan as Amici Curiae in Support of Defendant-Appellant, People v. Carp, No. 146478 (Mich. Feb. 14, 2014).

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