Summary of Argument

Miller v. Alabama gave hope to youth offenders sentenced to unconstitutionally long sentences that they might experience freedom instead of dying in prison. Miller’s promise was twofold: first, that individualized sentencing proceedings would account for their diminished culpability, and second, that a mechanism such as parole would provide a meaningful opportunity to obtain release. In many states, including Missouri, this promise has been illusory.

Mr. Williams’s sentence, as well as the sentences of four other petitioners whose certiorari petitions were filed contemporaneously, imposed prior to Miller, were mandatory sentences of life without parole. Missouri’s current parole process, enacted on the heels of Montgomery v. Louisiana, will not provide Mr. Williams with either an individualized sentencing proceeding or a meaningful opportunity to obtain release. Instead, Mr. Williams will receive an ill-defined, and perhaps single, opportunity to petition the parole board for release after serving twenty-five years. Missouri’s parole process lacks basic procedural guarantees, predictably leading to few instances of reprieve from the board.

Missouri is not alone its failure to provide Miller’s guarantees. Virginia claims that geriatric release provisions, which permit the possibility of release after an inmate reaches the age of 60, provide a meaningful opportunity to obtain release. North Carolina provides neither notice nor an opportunity to be heard in its parole process. Maryland, in the last two decades, has never granted parole to a juvenile offender sentenced to life.

This case presents an opportunity to ensure Miller’s requirement that children have a meaningful opportunity for release by stopping states from giving lip service to Miller through inadequate parole processes. In the alternative, this Court should grant Mr. Williams’s petition, vacate the Missouri Supreme Court’s dismissal, and remand the case to the Missouri courts to consider in the first instance whether Mo. Rev. Stat. § 558.047.1(1) (2016) in fact provides a meaningful opportunity for release for juvenile offenders who have received unconstitutionally long sentences, as mandated by this Court in Graham, Miller, and Montgomery.

Summary of Argument

Miller v. Alabama offered hope for youthful offenders sentenced to unconstitutionally lengthy prison terms, suggesting a possibility for release rather than life imprisonment. Miller outlined a two-pronged approach: individualized sentencing proceedings to consider diminished culpability and a viable mechanism, such as parole, for release. However, in numerous states, including Missouri, this promise has proven illusory.

Mr. Williams's sentence, along with those of four other petitioners who filed contemporaneous certiorari petitions, were mandatory life-without-parole sentences imposed prior to Miller. Missouri's current parole process, enacted in response to Montgomery v. Louisiana, fails to deliver either individualized sentencing proceedings or a meaningful opportunity for release to Mr. Williams. Instead, Mr. Williams will receive a single, undefined opportunity to petition the parole board after serving 25 years. Missouri's parole process lacks fundamental procedural safeguards, resulting in a predictable scarcity of reprieves granted by the board.

Missouri is not alone in failing to uphold Miller’s guarantees. Virginia relies on geriatric release provisions, permitting release after an inmate reaches 60, as a meaningful opportunity for release. North Carolina offers neither notice nor an opportunity to be heard during its parole process. In the last two decades, Maryland has never granted parole to a juvenile offender sentenced to life.

This case presents an opportunity to ensure Miller’s requirement of meaningful opportunities for release for children by preventing states from merely paying lip service to Miller through inadequate parole processes. Alternatively, the Court should grant Mr. Williams’s petition, overturn the Missouri Supreme Court’s dismissal, and remand the case to Missouri courts for an initial consideration of whether Mo. Rev. Stat. § 558.047.1(1) (2016) genuinely provides a meaningful opportunity for release for juvenile offenders sentenced to unconstitutionally lengthy terms, as mandated by the Court in Graham, Miller, and Montgomery.

Summary of Argument

The Miller v. Alabama case offered hope to young offenders sentenced to life in prison without the possibility of parole. Miller promised that sentencing would consider their diminished culpability and that a system like parole would allow for release. However, many states, including Missouri, have not fulfilled this promise.

Mr. Williams, along with other petitioners, was sentenced to life without parole before Miller. Missouri's current parole process, which was enacted in response to Montgomery v. Louisiana, does not provide individualized sentencing or a real opportunity for release. Instead, Mr. Williams has one limited chance to petition for parole after serving 25 years. The process lacks safeguards, leading to few successful paroles.

Other states like Virginia, North Carolina, and Maryland also fail to meet the requirements of Miller. Virginia relies on geriatric release, which allows for release after age 60, while North Carolina provides no notice or hearing in its parole process. Maryland has not granted parole to any juvenile offender sentenced to life in the last two decades.

This case allows the court to ensure Miller's mandate of a meaningful chance at release. The Court can prevent states from simply offering inadequate parole processes to meet the requirements of Miller. Alternatively, the Court should grant Mr. Williams's petition, reverse the Missouri Supreme Court's dismissal, and remand the case back to Missouri. The Missouri courts should determine whether the state's current parole process provides a genuine opportunity for release for young offenders sentenced to unconstitutionally long terms, as required by Graham, Miller, and Montgomery.

Summary of Argument

The Miller v. Alabama case gave young offenders hope that they might be released from prison someday instead of staying there for the rest of their lives. The case promised two things:

• The courts would consider their age and reduced responsibility when deciding their sentence.

• There would be a system, like parole, that would give them a real chance to get out of prison.

However, many states, including Missouri, have not kept these promises. Mr. Williams and four other people were given life sentences without parole before Miller was decided. Missouri's parole system, which was changed after the Montgomery v. Louisiana case, does not let Mr. Williams have a fair chance to get his sentence reviewed or to get released. He can only ask the parole board for release once he has served 25 years in prison. Missouri's parole system doesn't have any clear rules and doesn't often grant parole.

Other states are also not following the rules set by Miller. Virginia says that their system that lets prisoners get released when they are 60 years old is enough, but it doesn't give them a real chance to get out. North Carolina doesn't even tell prisoners about the parole system or let them say why they should be released. Maryland hasn't granted parole to any young offenders in 20 years.

This case is a chance to make sure that states follow Miller's ruling and give young offenders a real chance to get released from prison. If the Court doesn't rule in favor of Mr. Williams, they should send his case back to the Missouri courts to decide if Missouri's parole system really gives young offenders a chance to get out.

Summary of Argument

Miller v. Alabama was a court case that said it’s not fair to sentence young people to life in prison without the chance of getting out. The court said that judges should think carefully about each case and that there should be a way for these young people to ask for freedom later on.

But in some states, like Missouri, this isn’t happening. Mr. Williams and other people who were sentenced to life in prison before Miller were told they could never get out. Missouri now has a way for people to ask for parole, but it’s not a good one. Mr. Williams would have to wait 25 years before he could even ask, and it’s not clear how easy it would be to get out.

Other states have similar problems. Virginia has a rule that allows for release when people are 60, but it’s not clear if that’s enough. North Carolina doesn’t even give people a chance to be heard when they ask for parole. And in Maryland, no one under 18 who was sentenced to life has ever been let out on parole.

This case is about making sure that young people have a real chance to get out of prison, as the Miller case said they should. The court could tell states to fix their parole systems, or it could send Mr. Williams’s case back to Missouri to see if their parole system really gives people a chance at freedom.