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 Respondents were convicted of murder for offenses they committed as juveniles, they received mandatory life without parole sentences which, pursuant to Miller, are unconstitutional. Miller applies retroactively to these Respondents 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 juveniles are unconstitutional. The Court mandated individualized sentencing that considers the unique characteristics of youthfulness. This ruling has retroactive effect, applying to cases finalized after direct review, including those of the Respondents. This retroactive application is based on four key arguments. First, the Supreme Court has already applied Miller retroactively in the case of Kuntrell Jackson, which was reviewed collaterally. Second, Miller established a substantive rule, which, according to precedent, applies retroactively. Third, Miller represents a significant change in criminal procedure, making retroactive application appropriate. Finally, the continuing imposition of sentences deemed unconstitutional by Miller constitutes a violation of the Eighth Amendment.

Summary of Argument

The Supreme Court ruled in Miller v. Alabama that mandatory life without parole sentences for juvenile offenders are unconstitutional. Instead, the court requires judges to consider the unique factors of each juvenile's case when deciding on a sentence. This ruling applies retroactively, meaning it applies to cases that have already been decided, for the following reasons:

• The Supreme Court has already applied Miller retroactively in a similar case.

• Miller established a new rule of law that applies retroactively.

• Miller is a significant change in criminal procedure that should be applied retroactively.

• Continued sentences that violate the Eighth Amendment are themselves unconstitutional.

Summary of Argument

In the case of Miller v. Alabama, the Supreme Court ruled that it’s against the Constitution to automatically sentence a juvenile offender to life in prison without the possibility of parole. Instead, a judge must consider the individual circumstances of the young person's crime, taking into account their age and other factors.

In the case of the Respondents, who were convicted of murder as juveniles, they were given mandatory life sentences without parole. This is unconstitutional because of the Miller ruling.

The Miller decision should apply to cases like those of the Respondents, even if those cases have been decided in the past, for these key reasons:

• The Supreme Court already applied Miller retroactively (meaning it should apply to past cases) when it ruled in favor of Kuntrell Jackson, a case that was being reviewed after the initial ruling.

• The Miller ruling is a rule of law that is important for all cases, and so it should apply to cases in the past.

• The Miller ruling is a big change in criminal law that should be applied to past cases.

• Once the Court says a punishment is cruel and unusual for children, continuing to apply that punishment would be a violation of the Eighth Amendment (the part of the Constitution that prohibits cruel and unusual punishment). So a date on the calendar can’t suddenly make a sentence constitutional if the Supreme Court has already declared it unconstitutional.

Summary of Argument

The Supreme Court said that giving kids life in prison without the chance of ever getting out is wrong. They said judges need to look at each kid’s case and decide if they should get this punishment.

Two kids were given life without parole for crimes they did when they were young. The Court said this is wrong because of what they decided in a case called Miller. This new rule means that judges need to look at each kid’s case to decide if this punishment is right.

The Court said this new rule should be used for cases that happened in the past, even if they’ve already been decided. Here’s why:

• They’ve already used this rule in a similar case.

• The new rule is about what’s right, not just how things are done.

• This new rule is important for everyone, and it should be used in all cases.

• Keeping kids in prison forever after the Court said it’s wrong is also wrong. A date can’t make something wrong suddenly right.