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 Appellant Donte Lamar Jones was convicted of murder for offenses he committed as a juvenile, he received a mandatory life without parole sentence which, pursuant to Miller, is unconstitutional.

Miller applies retroactively to Appellant Jones and to other cases that have become final after the expiration of the period for direct review. 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. Fourth, 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. Finally, Appellant’s interest in receiving a constitutional sentence far outweighs the Commonwealth’s interest in finality.

Summary of Argument

In Miller v. Alabama, the Supreme Court ruled that mandatory life without parole sentences for juvenile offenders violate the Eighth Amendment's prohibition against cruel and unusual punishment. This decision necessitates individualized sentencing considerations, taking into account the unique characteristics of youth. Appellant Donte Lamar Jones, convicted of murder for offenses committed as a juvenile, received a mandatory life without parole sentence, deemed unconstitutional under Miller.

The retroactive application of Miller to Jones's case is warranted for several reasons. Firstly, the Supreme Court's retroactive application of Miller in Kuntrell Jackson demonstrates precedent for extending the ruling to cases on collateral review. Secondly, Miller established a substantive rule, which generally applies retroactively, as established by Supreme Court jurisprudence. Thirdly, Miller's status as a watershed rule of criminal procedure reinforces its retroactive applicability. Fourthly, the principle of preventing continued Eighth Amendment violations mandates retroactivity, as any prolonged imposition of a sentence deemed unconstitutional by the Court is itself a violation. Lastly, Jones's interest in a constitutional sentence outweighs the Commonwealth's interest in finality.

Summary of Argument

In Miller v. Alabama, the Supreme Court declared unconstitutional the mandatory imposition of life without parole sentences on juveniles. The court mandated that sentencing should reflect an individualized assessment of the juvenile's culpability, considering their unique developmental characteristics.

The Miller ruling applies retroactively to cases like Appellant Jones', who received a mandatory life without parole sentence for crimes committed as a juvenile. This retroactive application is supported by several legal arguments: the Supreme Court has already applied Miller retroactively in Kuntrell Jackson which was under collateral review; Miller established a substantive rule, generally applied retroactively; Miller represents a fundamental shift in criminal procedure; and applying Miller retroactively aligns with the Eighth Amendment's prohibition against cruel and unusual punishment.

Ultimately, the Appellant's right to a constitutional sentence outweighs the Commonwealth's interest in finality.

Summary of Argument

The Supreme Court case Miller v. Alabama stated that a judge cannot automatically give a juvenile offender a life sentence without the possibility of parole. The judge must consider the individual situation of the juvenile and their level of responsibility for the crime.

Donte Lamar Jones was convicted of murder as a juvenile and received a life sentence without parole. This sentence, according to Miller, is unconstitutional.

Miller should be applied to cases like Jones’s, even if the cases were decided before the Miller ruling. This is because:

• The Supreme Court already applied Miller to a similar case on appeal.

• Miller changed the law on how judges sentence juveniles, so it should apply to all cases.

• Miller is a major change to how the law is applied, so it should apply to all cases.

• If Miller is not applied retroactively, then the court is continuing to uphold a punishment that the court has already ruled unconstitutional.

• Jones’s right to a fair sentence outweighs the state’s interest in not reopening old cases.

Summary of Argument

Donte Lamar Jones was found guilty of murder when he was a young person. He was sentenced to life in prison without the possibility of ever getting out. The Supreme Court said that this type of sentence is not fair for kids.

The Supreme Court made a decision in another case called Miller, and that decision says that judges have to look at each young person's case carefully before sentencing them to life without parole.

Since the Miller decision, it applies to people like Jones who were sentenced before the decision was made. This means Jones' sentence might need to be changed.

There are a few reasons why Miller applies to Jones' case:

1. The Supreme Court already changed the sentence of another young person who got life without parole because of the Miller decision.

2. Miller says something important about the law, and this type of law usually applies to all cases.

3. Miller is a big change in how judges deal with young people who commit crimes, and big changes usually apply to all cases.

4. It's not fair to keep a sentence that the Supreme Court says is wrong.

5. Jones needs a fair sentence, and that's more important than the state wanting to keep the sentence as it is.