Summary of Argument

Amici agree with Petitioner that Miller v. Alabama, 132 S. Ct. 2455 (2012), is a substantive rule of criminal law because it categorically prohibits a mandatory sentence of life without parole for juvenile offenders. Miller therefore is not subject to Teague’s bar against applying new procedural rules on collateral review. Amici write separately to assert that, even if the Court classifies Miller as procedural, the decision is still retroactive as a watershed rule of criminal procedure. Under Teague v. Lane, 489 U.S 288 (1989), watershed rules of criminal procedure are exempted from the Court’s general ban on enforcing new criminal procedure rules in habeas.

In requiring an individualized sentencing hearing that provides consideration of a defendant’s youth and its attendant circumstances before sentencing juvenile offenders to die in prison, the Miller Court made clear its belief that such sentences would and should be rare. Miller v. Alabama, 132 S. Ct. 2455, 2469 (2012). The inescapable corollary of this assumption is that mandatorily sentencing juvenile offenders to life without parole is fundamentally unfair and impermissibly unreliable. Miller’s new rule of individualized sentencing is therefore cognizable on collateral review. See Teague v. Lane, 489 U.S. 288, 311 (1989).

Summary of Argument

Amici contend that the Supreme Court's decision in Miller v. Alabama (2012) constitutes a substantive rule of criminal law. This is because it categorically prohibits the imposition of mandatory life sentences without parole for juvenile offenders. As such, it is not subject to the bar against applying new procedural rules on collateral review established in Teague v. Lane (1989).

Even if Miller is classified as a procedural rule, amici argue that it qualifies as a "watershed rule of criminal procedure" under Teague. Watershed rules are exempted from the general ban on retroactive application of new criminal procedure rules in habeas corpus proceedings.

The Miller Court emphasized the need for individualized sentencing hearings that consider the unique circumstances of juvenile offenders before imposing life sentences without parole. This requirement reflects the Court's belief that such sentences should be rare. The corollary of this assumption is that mandatory life sentences without parole for juveniles are inherently unfair and unreliable.

Therefore, amici assert that the new rule of individualized sentencing established in Miller is cognizable on collateral review under Teague. This is because it addresses a fundamental aspect of fairness and reliability in sentencing juvenile offenders.

Summary of Argument

In 2012, the Supreme Court ruled in Miller v. Alabama that it is unconstitutional to sentence juvenile offenders to life in prison without the possibility of parole without first considering their individual circumstances.

The Court recognized that juveniles are different from adults in terms of their maturity, impulsivity, and potential for rehabilitation. The decision in Miller v. Alabama ensures that juvenile offenders have a meaningful opportunity to demonstrate their potential for change before being sentenced to die in prison.

Even though Miller v. Alabama is a new rule of criminal procedure, it is still applicable to cases that were already decided before the ruling. This is because the Court has determined that Miller v. Alabama is a "watershed rule of criminal procedure." Watershed rules are so fundamental to the fairness of the criminal justice system that they must be applied retroactively.

The Miller v. Alabama decision is a significant victory for juvenile offenders. It ensures that they will not be automatically sentenced to life in prison without parole, and that their individual circumstances will be considered before such a harsh sentence is imposed.

Summary of Argument

In the Miller v. Alabama case, the court decided that it's not fair to automatically sentence young people who commit crimes to life in prison without the chance for parole. This is because young people are still developing and have the potential to change.

Even if the court thinks Miller is a rule about how trials should be run, it's still a really important rule that should apply to everyone. This is because it's about making sure that sentences are fair and take into account the fact that young people are different from adults.

The Miller rule means that before a young person can be sentenced to life in prison without parole, there has to be a hearing where the judge considers their age and other factors, like their background and the circumstances of the crime. This gives young people a chance to show that they deserve a second chance.

The court believes that sentencing young people to die in prison without considering these factors is unfair and wrong. So, the Miller rule makes sure that young offenders get a fair shot at a better future.

Summary of Argument

The authors of this brief believe that a rule called Miller should apply to people who were sentenced to life in prison without parole when they were kids.

Miller says that judges can't automatically give kids life without parole. Instead, they have to have a special hearing where they think about the kid's age and other things before making a decision.

These friends say that Miller is a rule about fairness, not about how trials are run. So, it should apply to people who were sentenced before Miller was decided.

Even if Miller is not a rule about fairness, they say it's still a really important rule that should apply to old cases. That's because Miller says that it's not fair to automatically sentence kids to life without parole. It's like saying that all kids who steal candy should get the same punishment, no matter how old they are or why they stole it. That wouldn't be fair, right?

So, these friends believe that the Miller rule should help people who were sentenced to life without parole when they were kids, even if their cases are old.