Summary of Argument

In Miller v. Alabama, 132 S. Ct. 2455 (2012), the United States Supreme Court held that the mandatory imposition of life without parole sentences on juvenile offenders is unconstitutional. Instead, Miller requires that a sentencer make an individualized determination of the juvenile's level of culpability, taking into account the unique characteristics associated with his young age. When Appellee was convicted of first- degree felony murder for an offense he committed as a juvenile, he received a mandatory life without parole sentence which, pursuant to Miller, is unconstitutional. The Wyoming legislature's attempt to cure this constitutional defect by providing parole review after twenty-five years is insufficient because it fails to provide an individualized sentencing hearing - even though certain juvenile offenders may be denied the opportunity for parole review altogether. Because Miller requires an individualized sentencing hearing before a juvenile offender receives a life without parole sentence, this sentencing scheme is unconstitutional.

The parties agree that Appellee Mares, and others similarly situated, benefit from Wyoming's new legislation even though his conviction was final before the Miller decision and before the legislation was enacted. To the extent this Court still needs to resolve the question, Miller applies retroactively to Appellee and to other cases that have become final after the expiration of the period for direct review, for four primary reasons. First, the United States Supreme Court has already applied Miller retroactively by affording relief in Kuntrell Jackson's case, which was before the Court on collateral review. Second, Miller announced a substantive rule, which pursuant to Supreme Court precedent applies retroactively. Third, Miller is a watershed rule of criminal procedure that applies retroactively. Finally, Miller must be applied retroactively because, once the Court determines that a punishment is cruel and unusual when imposed on a child, any continuing imposition of that sentence is itself a violation of the Eighth Amendment; an arbitrary date on the calendar cannot deem a sentence constitutional which the United States Supreme Court has now declared cruel and unusual punishment.

Summary of Argument

In Miller v. Alabama, the Supreme Court ruled that mandatory life-without-parole sentences for juvenile offenders violate the Eighth Amendment's prohibition against cruel and unusual punishment. This decision mandates individualized sentencing hearings to assess the culpability of juvenile offenders, considering factors specific to their young age.

The Wyoming legislature attempted to address this constitutional issue by enacting legislation that provides parole review after twenty-five years for juvenile offenders sentenced to life without parole. However, this legislation falls short of the Miller requirement for individualized sentencing hearings. The failure to provide individualized hearings, coupled with the possibility of certain juveniles being denied parole review, renders the Wyoming legislation constitutionally deficient.

The parties acknowledge that the new legislation benefits individuals like Appellee Mares, whose convictions became final before Miller and the enactment of the legislation. The court's application of Miller retroactively to cases like Appellee's rests on four primary justifications:

1. The Supreme Court's retroactive application of Miller in Kuntrell Jackson demonstrates its willingness to afford relief on collateral review.

2. Miller announced a substantive rule, which, according to Supreme Court precedent, warrants retroactive application.

3. Miller represents a watershed rule of criminal procedure, necessitating retroactive application.

4. Continued imposition of life without parole sentences declared unconstitutional by Miller constitutes a violation of the Eighth Amendment. The arbitrary timing of a sentence cannot retroactively legitimize a punishment deemed cruel and unusual by the Supreme Court.

Summary of Argument

The Supreme Court case Miller v. Alabama (2012) ruled that mandatory life-without-parole sentences for juvenile offenders are unconstitutional. The court found that such sentences must be accompanied by an individualized assessment of the juvenile’s culpability, taking into account their age. The state of Wyoming, however, responded to Miller by enacting a law that allows for parole review after 25 years but still fails to ensure individualized sentencing hearings for all juvenile offenders. This new law, therefore, remains unconstitutional because it does not fully comply with Miller’s requirements for individualized sentencing.

The parties in this case agree that the new legislation benefits individuals like the Appellee, even though his conviction was finalized before the Miller decision and the legislation's enactment. It is also clear that Miller applies retroactively to the Appellee and similar cases, as the Supreme Court has already applied it retroactively in a case involving collateral review. Additionally, the Miller decision established a substantive rule, which according to Supreme Court precedent, should apply retroactively. Further, the Miller case is considered a watershed rule of criminal procedure, another factor that suggests retroactive application. Finally, retroactive application is necessary because once the court declares a punishment unconstitutional for juveniles, continuing to impose that sentence constitutes an ongoing violation of the Eighth Amendment. This means that setting an arbitrary date for the law’s application does not make an unconstitutional sentence suddenly acceptable.

Summary of Argument

In the case of Miller v. Alabama, the Supreme Court ruled that automatically giving life in prison without the chance of parole to young people who commit crimes is against the Constitution. The Court said that judges must consider each case individually, looking at things like the young person's age and the details of the crime.

When Appellee (the defendant in this case) was convicted of murder as a young person, he was automatically given life in prison without parole. This sentence, according to Miller, is unconstitutional. Wyoming tried to fix this by allowing for parole after 25 years, but this isn't enough because it doesn't include a hearing where each individual case is considered. Miller requires this type of hearing before a young person can be given a life sentence without parole.

Both sides agree that Appellee and other people in similar situations benefit from Wyoming's new law even though his case was already decided before the Miller decision. While there may be some debate about whether Miller applies to cases that were decided before it, the Supreme Court has said it does for a few reasons. First, the Court used Miller to give relief in another case on appeal. Second, Miller is a major rule that changes how sentences are decided, and these types of rules apply to past cases. Third, Miller is a very important ruling about criminal justice, and these types of rulings apply to past cases. Finally, Miller should apply to past cases because once the Court says a punishment is cruel and unusual for children, continuing to use that punishment is also a violation of the Constitution.

Summary of Argument

The Supreme Court said that it's not fair to give young people life in prison without ever being able to get out. They said that judges have to look at each case carefully and decide if the young person is really so bad that they can't ever be free again.

A young person named Kuntrell Jackson in Wyoming got life in prison without parole. That's against the law because the judge didn't look at his case carefully. Wyoming changed the law so that people like him could be considered for parole after 25 years. But, that's still not fair because the judge didn't get to look at his case carefully before he got the sentence.

Everyone agrees that this new law helps people like this young person, even though he was already in prison before the law changed. The Supreme Court has already said that this new rule about young people in prison applies to everyone, even if they were already in prison. This rule is important because it protects people from being punished too harshly. It would be unfair to say that it's okay to keep someone in prison forever just because the law changed after they were already in prison.