Summary of Argument

In Miller v. Alabama, 132 S. Ct. 2455 (2012), the United States Supreme Court held that the mandatory imposition of sentences of life without the possibility of parole on juvenile offenders convicted of murder is unconstitutional. At the time the Petitioner Gary Griffin was sentenced for a crime he committed as a juvenile, state law mandated that he be sentenced to life without parole. As applied to juvenile offenders, this mandatory scheme is unconstitutional pursuant to Miller.

Miller applies retroactively to the Petitioner, as well as to all other similarly situated individuals, including several additional petitioners with cases pending before this Court. See Lockhart vs. Norman, No. SC93335; McElroy vs. Bowersox, No. SC93465; and Collier v. Norman, No. SC92980. Miller announced a substantive rule, which pursuant to U.S. Supreme Court precedent applies retroactively. Further, even assuming the rule is procedural, Miller is a watershed rule of criminal procedure that applies retroactively. Moreover, 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; the date upon which a mandatory life without parole sentence is imposed cannot convert it into a constitutional sentence.

Summary of Argument

In Miller v. Alabama, the Supreme Court ruled that mandatory life without parole sentences for juvenile offenders convicted of murder are unconstitutional. This case challenges the constitutionality of a state law mandating such sentences, specifically as applied to the petitioner, Gary Griffin, who was sentenced for a crime committed as a juvenile.

The Miller decision applies retroactively, affecting not only Griffin but also other individuals in similar situations, including those involved in cases currently pending before the court (Lockhart vs. Norman, McElroy vs. Bowersox, and Collier v. Norman). This retroactive application stems from the fact that Miller established a substantive rule, which, according to Supreme Court precedent, applies retroactively. Even assuming the rule to be procedural, Miller represents a watershed rule of criminal procedure, warranting retroactive application.

Furthermore, retroactive application of Miller is necessary because imposing a punishment deemed cruel and unusual for children constitutes an ongoing violation of the Eighth Amendment. The date of sentencing does not render a mandatory life without parole sentence constitutional.

Summary of Argument

The case of Miller v. Alabama, decided by the Supreme Court in 2012, held that mandatory life sentences without parole for juvenile offenders convicted of murder are unconstitutional. This ruling has significant implications for individuals like the Petitioner, Gary Griffin, who was sentenced to life without parole under a state law that mandated such sentences for juveniles.

The Supreme Court's decision in Miller applies retroactively, meaning it affects past cases. This retroactivity extends not only to the Petitioner's case but also to several other individuals similarly situated, as seen in pending cases like Lockhart vs. Norman, McElroy vs. Bowersox, and Collier v. Norman. The Court's rationale for retroactivity stems from the fact that Miller established a substantive rule, a fundamental change in the law, which generally applies retroactively. Even if considered a procedural rule, Miller qualifies as a watershed rule, a significant change in criminal procedure, also subject to retroactive application.

Furthermore, the principle of retroactivity is essential in this context because the Court's ruling in Miller declares a sentence unconstitutional when applied to a juvenile offender. Continuing to impose such a sentence, regardless of the date it was initially imposed, constitutes a violation of the Eighth Amendment, which prohibits cruel and unusual punishment. Therefore, any mandatory life without parole sentence imposed on a juvenile, regardless of when it occurred, must be reviewed and potentially modified in light of the Miller decision.

Summary of Argument

In 2012, the Supreme Court ruled in Miller v. Alabama that it is against the Constitution to automatically sentence a young person convicted of murder to life in prison without the possibility of parole. The Supreme Court found this mandatory punishment scheme unconstitutional.

The Supreme Court’s ruling in Miller applies to past cases, including Gary Griffin’s. Gary Griffin received a mandatory life-without-parole sentence when he was a young person. The Supreme Court also ruled that Miller applies to other people in similar situations, like the petitioners in Lockhart vs. Norman, McElroy vs. Bowersox, and Collier v. Norman.

The Supreme Court’s ruling in Miller is considered a "substantive rule," which is a type of rule that applies to past cases. Even if Miller were considered a "procedural rule," it would still apply to past cases because it is a major change in criminal law.

Miller must be applied to past cases because continuing to punish someone with a life sentence without parole after the Supreme Court has decided it is cruel and unusual violates the Eighth Amendment (which prohibits cruel and unusual punishment). The date of sentencing does not make a mandatory life-without-parole sentence legal if it has already been deemed unconstitutional.

Summary of Argument

The Supreme Court said that it’s not fair to give kids who commit murder a life sentence without any chance of getting out of prison. This is because kids are different from adults, and they can change.

Gary Griffin was given this kind of sentence when he was a kid. The Supreme Court’s decision means that his sentence is no longer allowed. It also means that other kids who got the same kind of sentence can ask to have their sentences changed.

The Court said that this decision applies to cases that happened in the past, even if the sentences were given before the decision was made. This is because the sentence is considered cruel and unusual punishment for kids.