Summary of Argument

In Miller v. Alabama, 567 U.S. , 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 Petitioner was sentenced for crimes he committed as a juvenile, federal law mandated a life without parole sentence for his murder-based offenses. As applied to juvenile offenders, this mandatory scheme is unconstitutional pursuant to Miller.

First, the United States Supreme Court has already answered the question of retroactivity by applying Miller to Kuntrell Jackson’s case, which was before the court on collateral review. Moreover, Miller announced a substantive rule, which is consistent with the Supreme Court’s interpretation of the Eighth Amendment in light of its evolving understanding and appreciation of the significance of child and adolescent development. Further, because the Miller Court found a violation of the Eighth Amendment, the rule announced necessarily must provide retroactive relief. If the Court determines that a punishment is cruel and unusual, it inescapably deems the same punishment, albeit imposed before the decision, similarly cruel and unusual; nothing about the nature of the punishment or its disproportionality is lessened by the date upon which it was imposed. In other words, categorically, any Eighth Amendment decision barring a particular sentence must be retroactive, including Miller. Finally, even assuming the rule is procedural, Miller is a “watershed rule[] of criminal procedure” under Teague v. Lane, 489 U.S. 288, 300 (1989). For each of these reasons, and as this Court and others have already found, the holding in Miller applies retroactively to inmates, such as Petitioner, serving mandatory life without parole sentences for crimes committed as juveniles who have exhausted both direct and collateral appeal rights and seek to file a successive petition pursuant to 28 U.S.C. § 2244(b).

Summary of Argument

In Miller v. Alabama, the Supreme Court held that mandatory life without parole sentences for juveniles convicted of murder violate the Eighth Amendment. This case addresses the retroactivity of Miller in the context of a petitioner seeking a successive petition under 28 U.S.C. § 2244(b).

The Court's decision in Miller constitutes a substantive rule, as it reflects the evolving understanding of the Eighth Amendment and the developmental characteristics of juveniles. This interpretation is consistent with the Court's jurisprudence in Graham v. Florida and Roper v. Simmons. Additionally, the Miller Court's finding of an Eighth Amendment violation necessitates retroactive application. A punishment deemed cruel and unusual at the time of a decision cannot be considered any less cruel and unusual when imposed prior to that decision.

Therefore, any Eighth Amendment ruling prohibiting a particular sentence must be applied retroactively, including the holding in Miller. Even if considered procedural, Miller qualifies as a “watershed rule[] of criminal procedure” under Teague v. Lane, warranting retroactive application.

These arguments, in conjunction with previous judicial precedent, support the retroactive application of Miller to inmates serving mandatory life without parole sentences for juvenile offenses. This allows for the review of such sentences for individuals who have exhausted both direct and collateral appeals and seek a successive petition under 28 U.S.C. § 2244(b).

Summary of Argument

In Miller v. Alabama, the Supreme Court ruled that mandatory life sentences without parole for juveniles convicted of murder are unconstitutional. This decision impacts Kuntrell Jackson's case, as he was sentenced under a federal law that mandated such sentences for murder-based offenses committed as a juvenile.

The Supreme Court's decision in Miller is retroactive, meaning it applies to cases that were decided before the ruling. This is because the Court announced a substantive rule, which means it changed the understanding of the Eighth Amendment's prohibition on cruel and unusual punishment. The Court's evolving understanding of juvenile development led to this change, recognizing the unique vulnerabilities of minors.

This retroactive application is consistent with the Court's precedent on Eighth Amendment violations. If a punishment is deemed cruel and unusual, it remains so regardless of when it was imposed. This logic extends to Miller, as the Court's finding that mandatory life without parole for juveniles violates the Eighth Amendment necessarily means it applies retroactively.

Even if considered a procedural rule, Miller qualifies as a "watershed rule" under Teague v. Lane, meaning it applies to cases on collateral review. Therefore, inmates like Kuntrell Jackson who are serving mandatory life without parole sentences for crimes committed as juveniles, and who have exhausted their appeals, are eligible to file a successive petition under 28 U.S.C. § 2244(b) based on Miller.

Summary of Argument

In the case of Miller v. Alabama, the Supreme Court ruled that it is against the Constitution to automatically sentence young people convicted of murder to life in prison without the possibility of parole. This ruling was made in 2012. The person asking for the court to review his sentence (the Petitioner) was sentenced to life without parole for a crime he committed as a young person. This sentence was based on a law that required this type of sentence for certain crimes. The Court found that this law violated the Constitution when applied to young people because of how the Court understands the way young people develop.

The Supreme Court has already applied the Miller decision to another case on review, showing that it applies to cases already decided. The Court’s ruling in Miller is about the actual meaning of the law, not just how the law is applied. This aligns with the Court’s understanding of what is cruel and unusual punishment based on its evolving view of how young people grow. Since the Miller case found a violation of the Constitution’s Eighth Amendment, the ruling must apply to past cases. If a punishment is deemed cruel and unusual, it’s still cruel and unusual even if it was given out before the decision. In other words, any ruling based on the Eighth Amendment that says a certain sentence is unconstitutional must apply to past cases. This includes the ruling in Miller.

Even if the Miller ruling is considered a procedural rule, it is a "watershed" rule, meaning it is a very important change in criminal law. This is based on another Supreme Court case, Teague v. Lane. For all of these reasons, courts, including this one, have decided that the Miller decision applies to people serving life without parole sentences for crimes committed as young people who have already gone through the regular appeal process and are now asking to file a new appeal.

Summary of Argument

In 2012, the Supreme Court said that it is not okay to give kids who commit murder a sentence of life in prison without the chance of getting out. This is because kids are different from adults and may not understand the full consequences of their actions. This means that kids and teens who were given that sentence before the law changed might be able to get a new trial or a shorter sentence.