Summary of Argument

In Miller v. Alabama, 567 U.S. 460 (2012), this Court concluded that a sentence of life without the possibility of parole is a cruel and unusual punishment for most juvenile offenders. Because juveniles have “diminished culpability and greater prospects for reform,” id. at 471, this harshest of sentences is disproportionate except in the rare circumstance where a juvenile is incorrigible, with no capacity for potential rehabilitation. As Montgomery v. Louisiana explained, a state’s sentencing scheme must “give effect[] to Miller’s substantive holding that life without parole is an excessive sentence for children whose crimes reflect transient immaturity.” 136 S. Ct. 718, 735 (2016).

Virginia’s sentencing scheme does not satisfy these requirements. When a Virginia court sentences a juvenile offender for capital murder, there is no meaningful procedure by which the court engages in the individualized inquiry that Miller requires. As this case illustrates, juvenile offenders in Virginia routinely receive life-without-parole sentences without any court making an individualized assessment that takes account of the offender’s youth and whether the child is irreparably corrupt.

The Warden does not dispute the reality of how Virginia’s sentencing scheme works in practice. Nor does he deny that the sentencing court in this case never undertook an individualized assessment that considered the defendant’s youth and his capacity for rehabilitation. Instead, the Warden urges the Court to limit Miller to “mandatory” life-without-parole sentences and argues that Virginia’s sentencing scheme is “discretionary” because courts have residual authority to suspend a sentence. But Virginia courts very rarely use their suspension power, and nothing compels them to engage in the individualized inquiry that Miller requires. If the Warden’s position is accepted, the substantive rule of constitutional law that Miller recognizes will be rendered ineffectual for juvenile offenders in Virginia. Instead of being a rare exception, life-without-parole sentences for juveniles will remain commonplace, imposed in virtually every capital-murder case in which they are proposed.

This Court should not countenance the Warden’s attempt to carve out a large, unwarranted exception to the constitutional guarantee that Miller recognized as beyond a State’s power to evade. Instead, the Court should hold that because the sentencing court in this case did not undertake an individualized inquiry into the defendant’s youth and his capacity for rehabilitation, re-sentencing is required. The Court should affirm the Fourth Circuit’s judgment.

Summary of Argument

In Miller v. Alabama (2012), the Supreme Court held that life without parole (LWOP) sentences for juvenile offenders violate the Eighth Amendment's prohibition against cruel and unusual punishment. The Court recognized the diminished culpability and greater potential for rehabilitation of juveniles, making LWOP disproportionate except for the rarest cases of incorrigible offenders.

Virginia's sentencing scheme for juvenile capital murder cases fails to meet the requirements of Miller. Courts routinely impose LWOP sentences without conducting individualized assessments of the offender's youth and capacity for rehabilitation.

The Warden argues that Miller only applies to mandatory LWOP sentences and that Virginia's scheme is discretionary because courts have the authority to suspend sentences. However, this authority is rarely exercised, and courts are not compelled to engage in the individualized inquiry required by Miller.

Allowing the Warden's exception would effectively nullify Miller in Virginia, resulting in the continued imposition of LWOP sentences on juveniles without consideration of their individual circumstances. The Court should reject this attempt to evade the constitutional guarantee and require re-sentencing in cases where the sentencing court failed to conduct an individualized inquiry into the defendant's youth and capacity for rehabilitation.

Summary of Argument

In the case of Miller v. Alabama, the Supreme Court ruled that sentencing juveniles to life in prison without the possibility of parole is cruel and unusual punishment in most cases. This decision was based on the understanding that juveniles are less responsible for their actions and have a greater potential for rehabilitation than adults.

Virginia's Sentencing System for Juveniles

However, Virginia's sentencing system does not adequately protect juvenile offenders. When a juvenile is convicted of capital murder in Virginia, the court does not typically consider the offender's age or potential for rehabilitation before imposing a life-without-parole sentence.

The Warden's Argument

The Warden in this case argues that Virginia's system is not unconstitutional because courts have the option to suspend sentences. However, this power is rarely used, and there is no requirement for courts to consider the juvenile's individual circumstances.

The Importance of Individualized Sentencing

If the Warden's argument is accepted, many juvenile offenders in Virginia will continue to receive life-without-parole sentences, even though the Supreme Court has ruled that this punishment is excessive in most cases.

Conclusion

The Court should not allow Virginia to create an exception to the constitutional protections afforded to juvenile offenders. The sentencing court must consider the juvenile's age and potential for rehabilitation before imposing a life-without-parole sentence.

Summary of Argument

In the case of Miller v. Alabama, the Supreme Court ruled that it's cruel and unusual to sentence most young offenders to life in prison without the chance of parole. This is because young people are less responsible for their actions and have a better chance of changing for the better.

The Problem in Virginia:

Virginia's laws don't follow this rule. When a young person is convicted of a serious crime, they often get a life sentence without parole without any consideration of their age or potential for rehabilitation.

The Argument:

The person in charge of the prison (the Warden) argues that Virginia's laws are okay because judges have the power to give shorter sentences. However, judges rarely use this power, and there's nothing that forces them to consider the youth and potential of the offender.

The Solution:

The court should rule that the young offender in this case needs to be re-sentenced because the judge didn't consider his age and potential for rehabilitation. This would ensure that young offenders in Virginia get a fair chance at a better future, as required by the Supreme Court's ruling in Miller v. Alabama.

Summary of Argument

The Supreme Court said that most kids who commit crimes shouldn't get the worst punishment, which is life in jail without ever getting out. This is because kids are still growing and changing, and they might be able to become better people.

But in Virginia, kids who commit serious crimes often get life without parole. The courts don't always look at each kid and decide if they're really bad and can't change. In this case, a kid was sentenced to life without parole, but the court never checked if he was too young or could still improve.

The groups arguing the case says that Virginia's way of sentencing kids is wrong because it doesn't follow the Supreme Court's rule. If the court agrees, then the kid in this case will have to be sentenced again.

The court should make sure that kids only get life without parole if they're really bad and can't change. Otherwise, it's not fair to the kids.