Summary of Argument

The Court initially addressed life without parole for juvenile homicide offenders in Miller. In that decision, the Court required a sentencing court “to take into account how children are different, and how those differences counsel against irrevocably sentencing them to a lifetime in prison” and concluded that no juvenile may be sentenced to life without parole for a crime that reflects “unfortunate yet transient immaturity,” rather than “irreparable corruption.” 567 U.S. at 480 (internal quotation marks omitted).

The Court held that the Miller ruling was a substantive rule of constitutional law in Montgomery. The issue in Montgomery was limited to whether Miller was retroactive on collateral review. Citing Miller, the Court again explained that a life without parole sentence violates the Eighth Amendment except for “the rare juvenile offender whose crime reflects irreparable corruption.” Montgomery, 136 S. Ct. at 734 (citing Miller, 567 U.S. at 479-480). The Court held that Miller announced a new “substantive rule of constitutional law” rendering life without parole an unconstitutional penalty for a class of defendants “whose crimes reflect the transient immaturity of youth.” Montgomery, 136 S. Ct. at 734. Accordingly, the Court held that the Miller decision was retroactive to collateral challenges to convictions. Ibid.

This case presents no new issues for the Court. The Court simply needs to reaffirm its holding in Miller that no juvenile may be sentenced to life without parole for a crime that reflects transient immaturity rather than irreparable corruption.

For the Court to decide otherwise would violate fundamental rule of law principles. The rule of law, which is “indispensable” for a just society, is secured by the Supremacy Clause and held sacrosanct by the Court. Moreover, a decision undercutting Miller could upset numerous state sentencing legislative acts and judicial decisions that relied upon the Court’s Miller decision.

The ABA urges the Court to reaffirm what it already held in Miller, safeguard the rule of law, and affirm the judgment below.

Summary of Argument

In Miller v. Alabama (2012), the Supreme Court addressed the constitutionality of life sentences without parole for juvenile homicide offenders. The Court held that such sentences violate the Eighth Amendment's prohibition against cruel and unusual punishment, except in cases where the offender's crime reflects "irreparable corruption."

Montgomery and Retroactivity

In Montgomery v. Louisiana (2016), the Court extended Miller, holding that its ruling was a substantive rule of constitutional law that applied retroactively to collateral challenges to convictions. The Court emphasized that life without parole sentences for juveniles whose crimes reflect "transient immaturity" are unconstitutional.

Current Case

The present case raises the question of whether the Court should reaffirm its holding in Miller. The argument in favor of reaffirmation is based on the following principles:

Rule of Law

The rule of law, enshrined in the Supremacy Clause, is fundamental to a just society. Upholding Miller would safeguard this principle.

Reliance Interests

Numerous state legislatures and courts have relied on Miller in reforming sentencing laws and practices. Overturning Miller could disrupt these efforts.

Conclusion

The Court should reaffirm its holding in Miller that life sentences without parole for juveniles whose crimes reflect transient immaturity are unconstitutional. This would uphold the rule of law and protect the rights of juvenile offenders.

Summary of Argument

In the Miller case, the Supreme Court ruled that sentencing juveniles to life without parole was unconstitutional unless their crimes showed they were permanently corrupt. This decision was based on the idea that children are different from adults and their immaturity should be considered in sentencing.

The Montgomery Case

The Montgomery case extended the Miller ruling, making it retroactive. This meant that people who had been sentenced to life without parole as juveniles could now challenge their sentences.

Current Case

The current case is similar to Miller and Montgomery. The issue is whether a juvenile can be sentenced to life without parole for a crime that reflects immaturity rather than permanent corruption.

Arguments in Favor of Reaffirming Miller

• Rule of Law: The Supreme Court has already ruled on this issue in Miller. Overturning that decision would violate the principle of the rule of law, which protects citizens from arbitrary government action.

• Reliance on Miller: Many states have changed their sentencing laws based on the Miller decision. Overturning Miller would disrupt these laws and create uncertainty.

Conclusion

The Court should reaffirm its holding in Miller and prohibit life sentences without parole for juveniles whose crimes reflect immaturity. This would uphold the rule of law and protect the rights of children.

Summary of Argument

In the past, courts could sentence kids who committed murder to life in prison without the possibility of parole (getting out early). But the Supreme Court has ruled that this is unfair for most young offenders.

The Court's Reasoning

The Court believes that kids are different from adults. They're still developing and may not fully understand the consequences of their actions. So, it's not right to lock them away forever for something they did when they were young and immature.

The Rule

The Court has said that kids can only be sentenced to life without parole if their crime shows that they are beyond help and will never change.

Why This Matters

This rule is important because it protects kids from being treated too harshly. It also ensures that the law is fair and just.

What's at Stake

If the Court changes its mind, it could mean that more kids are sentenced to life in prison without any chance of getting out. This would be a step backward for fairness and justice.

Conclusion

The Court should stick to its original ruling and protect kids from unfair sentences.

Summary of Argument

In a case called Miller, the Supreme court said that kids are different from adults and shouldn't get life in prison without a chance to get out if their crime was just because they were young and not thinking clearly.

Later, in a case called Montgomery, the court said that Miller's law was really important and that even kids who were already in prison for life should get a chance to show that they've changed and deserve to get out.

Now there's another case where the court has to decide if they still agree with Miller.

Some people think it's important to follow the rules and not change them. They also think that if the court changes its mind, it could mess up a lot of laws and decisions that were made based on Miller.

But others say that it's not fair to keep kids in prison forever for things they did when they were young and didn't understand the consequences. They also say that it's important to protect the rule of law, which means that everyone should be treated fairly and according to the rules.

The court has to decide what's more important: following the old rules or being fair to kids.