Summary of Argument

Amici curiae represent faith-based organizations comprised of members withdiverse backgrounds, traditions, and perspectives, as well as leaders of different religious denominations.2Despite their varied religious affiliations and traditions, amid share the common and firm belief that the United States Supreme Court's opinion in Miller v. Alabama,US_; 132 S Ct 2455; 183 L Ed 407 (2012), should be applied to the cases of Raymond Curtis Carp, Cortez Roland Davis, and Dakotah Wolfgang Eliason so that each receives an individualized sentencing that allows the court to consider fully the mitigating factors such asyouth and the capacity for rehabilitation.

In Miller v. Alabama, the Court held that "the Eighth Amendment forbids asentencing scheme that mandates life in prison without possibility of parole for juvenile offenders." 132 S Ct at 2469. In the decisions below, the Court of Appeals determined incorrectly that Miller does not apply retroactively to cases on collateral review or, in one case, that the only option for resentencing was life with or life without the possibility of parole.

Faith-based organizations and religious leaders offer unique insights into the application of the Eighth Amendment, which necessarily requires courts to scrutinize the morality of a punishment, either facially or as applied to certain circumstances. As the United States Supreme Court explained in Atkins v. Virginia, 536 US 304; 122 S Ct 2242; 153 L Ed 335(2002), the views of religious groups about the morality of a particular punishment can provide evidence of a "broad[} social and professional consensus, " id. at 316 n. 21; 2249 n. 21, concerning the moral and ethical treatment of people convicted of crimes. Accordingly, theundersigned faith-based organizations and religious leaders wish to show that, in addition to being supported by the United States Supreme Court's precedents, retroactive application of Miller to cases on collateral review is also the morally correct decision that complies with the ideals underlying the Eighth Amendment.

Summary of Argument

Amici curiae, representing diverse faith-based organizations and religious leaders, argue that the Supreme Court's holding in Miller v. Alabama (2012) should be applied retroactively to the cases of Raymond Curtis Carp, Cortez Roland Davis, and Dakotah Wolfgang Eliason. Miller prohibits mandatory life sentences without parole for juvenile offenders.

Retroactivity of Miller

The Court of Appeals erred in holding that Miller does not apply retroactively to cases on collateral review. The Supreme Court has consistently held that new constitutional rules of criminal procedure apply retroactively to cases on collateral review.

Moral and Ethical Considerations

Faith-based organizations and religious leaders emphasize the moral imperative of considering mitigating factors, such as youth and rehabilitation potential, in sentencing. The Eighth Amendment prohibits cruel and unusual punishment, and the views of religious groups on the morality of punishment provide evidence of societal consensus.

Conclusion

Amici curiae urge the court to apply Miller retroactively to the cases of Carp, Davis, and Eliason, allowing for individualized sentencing that takes into account their youth and capacity for rehabilitation. This decision would align with both legal precedent and the moral principles underlying the Eighth Amendment.

Summary of Argument

Religious organizations and leaders believe that the Supreme Court's decision in Miller v. Alabama should apply to three specific cases: Raymond Curtis Carp, Cortez Roland Davis, and Dakotah Wolfgang Eliason. Miller ruled that it is unconstitutional to sentence juvenile offenders to life in prison without the possibility of parole.

Faith-based organizations and religious leaders emphasize the importance of considering morality when sentencing individuals. They believe that the views of religious groups can provide insight into what society considers ethical and moral.

These groups argue that applying Miller to the three cases in question is not only legally sound but also morally right. They believe that young offenders should have the opportunity for rehabilitation and a chance to reintegrate into society. They emphasize the importance of considering factors such as the offender's age and capacity for change when determining an appropriate sentence.

Summary of Argument

Religious groups and leaders believe that young people who commit crimes should have a chance at a fair sentence. They point to a Supreme Court case called Miller v. Alabama that said it's unconstitutional to automatically sentence young offenders to life in prison without the possibility of parole.

Religious groups believe that it's important to consider the morality of punishments. They argue that it's not right to treat all young offenders the same, regardless of their age or potential for rehabilitation.

These groups want the Miller decision to apply to cases that are currently being reviewed. This would mean that young offenders like Raymond Curtis Carp, Cortez Roland Davis, and Dakotah Wolfgang Eliason would have a chance at a sentence that takes into account their age and ability to change.

Summary of Argument

Leaders of different religions have come together to ask the court to give fair sentences to three young people named Raymond, Cortez, and Dakotah.

A long time ago, the Supreme Court said that young people who commit crimes should not be sentenced to life in prison without the chance to get out. But the courts that sentenced Raymond, Cortez, and Dakotah did not follow this rule.

The religious leaders believe that it is important to think about what is right and wrong when deciding on a punishment. They say that it is not fair to give these young people the same punishment as adults, because they are still young and have the chance to change and become better people.

They want the courts to give Raymond, Cortez, and Dakotah a chance to show that they can change and deserve a second chance.