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 Respondent, Frank Vigil, Jr., was sentenced for a crime he committed at age 16, 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 Respondent. 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 held that mandatory life without parole sentences for juvenile offenders convicted of murder are unconstitutional. The Respondent, Frank Vigil, Jr., was sentenced under a state law that mandated life without parole for his crime, which he committed at age 16. This mandatory sentencing scheme is unconstitutional under Miller.

Miller applies retroactively to the Respondent. Miller announced a substantive rule, which, according to Supreme Court precedent, applies retroactively. Even if the rule is procedural, Miller is a watershed rule of criminal procedure that applies retroactively. Additionally, Miller must be applied retroactively because once the Court determines a punishment is cruel and unusual for a child, its continued imposition is an Eighth Amendment violation. The date of a mandatory life without parole sentence does not render it constitutional.

Summary of Argument

In Miller v. Alabama, the Supreme Court ruled that mandatory life sentences without the possibility of parole for juvenile offenders convicted of murder are unconstitutional. This ruling has direct implications for Frank Vigil, Jr., who was sentenced to life without parole for a crime he committed at age 16 under a state law that mandated such a sentence.

The Miller decision applies retroactively to Vigil's case. The Supreme Court has established that substantive rules, like the one in Miller which addresses the constitutionality of a sentencing scheme, apply retroactively. Even if Miller is considered a procedural rule, it is a watershed rule of criminal procedure and thus still applies retroactively. Further, the Court's finding that life without parole sentences for juveniles are unconstitutional requires that the rule be applied retroactively. Any continued imposition of such a sentence after Miller would be a violation of the Eighth Amendment. The date of the sentence does not change its unconstitutionality.

Summary of Argument

The Supreme Court case Miller v. Alabama decided that it is unconstitutional to automatically sentence young people convicted of murder to life in prison without the possibility of parole. Frank Vigil, Jr. was sentenced to life without parole when he was 16 years old, based on a state law that required this sentence. Since Miller, this kind of mandatory sentence for juveniles is against the Constitution.

The Miller decision applies to Frank Vigil's case, even though he was sentenced before the decision was made. This is because Miller changed the law itself, and such changes usually apply to cases that happened before the decision. Even if Miller is seen as a change in procedure, it was a very important change in how the legal system handles criminal cases, so it applies to past cases.

The Miller decision must apply retroactively because continuing to keep someone in prison under a sentence that the Court has found unconstitutional is a violation of the Eighth Amendment, which prohibits cruel and unusual punishment. The fact that Vigil was sentenced before the decision was made doesn't change the fact that his sentence is illegal.

Summary of Argument

In 2012, the Supreme Court said that it's against the law to give kids who commit murder a life sentence in prison without the chance of ever getting out. This means that a law in the state where Frank Vigil, Jr. lived was wrong. He got a life sentence for something he did when he was 16 years old. The Supreme Court's decision, called Miller, applies to Frank, even though he was sentenced before the decision.

The Supreme Court decided that Miller is a really important rule that changes how the law works. This means that the rule goes back in time and applies to cases like Frank's. Even if Miller is about how laws are used, the Court said that it's super important and needs to go back in time.

Also, the Court said that once a punishment is found to be unfair to a child, it's always unfair. So, it doesn't matter when Frank got his sentence; it's still not right.