Summary of Argument

This Court’s determination in Miller v. Alabama, 132 S. Ct. 2455 (2012), that it is cruel and unusual to impose a mandatory life-without-parole sentence on a child under the age of 18 must be applied retroactively to all cases where that punishment has been imposed. Miller categorically prohibited an automatic life-without-parole sentence for an entire class of criminal defendants: those who were “under the age of 18 at the time of their crimes.” Id. at 2460. As such, it is a substantive rule. Miller is no different than the Eighth Amendment precedents on which it relied, which have universally been applied retroactively because the determination that a punishment is cruel and unusual is inexorably a substantive one.

This Court can and should find that Miller is retroactive in this case because this Court unquestionably has jurisdiction here. The Louisiana Supreme Court explicitly relied only on federal law in reaching its determination that Miller is not retroactive and that is sufficient for this Court’s review. But even if Louisiana had purported to rely on state law, state courts cannot, consistent with basic norms of constitutional adjudication, refuse to provide a remedy for constitutional violations that fall within Teague’s exceptions.

Summary of Argument

In Miller v. Alabama (2012), the Supreme Court held that the Eighth Amendment prohibits mandatory life-without-parole sentences for juveniles. This article argues that Miller should be applied retroactively to all cases involving such sentences.

Substantive Nature of Miller Rule

Miller established a categorical prohibition against automatic life-without-parole sentences for juveniles, constituting a substantive rule. Like the Eighth Amendment precedents it relied upon, Miller has been universally applied retroactively because the determination of cruel and unusual punishment is inherently substantive.

Jurisdiction and Retroactivity

The Supreme Court has jurisdiction to review the Louisiana Supreme Court's determination that Miller is not retroactive, as it relied solely on federal law. Even if state law had been invoked, state courts are obligated to remedy constitutional violations that fall within the exceptions to the Teague doctrine, which generally prohibits retroactive application of new constitutional rules.

Conclusion

The substantive nature of the Miller rule and the Court's jurisdiction in this case necessitate its retroactive application to all cases where life-without-parole sentences were imposed on juveniles.

Summary of Argument

In the 2012 case of Miller v. Alabama, the Supreme Court ruled that it is unconstitutional to automatically sentence children under 18 to life in prison without the possibility of parole. This decision was based on the Eighth Amendment, which prohibits cruel and unusual punishment.

The question now is whether the Miller decision should be applied retroactively, meaning that it would apply to people who were sentenced to life without parole as minors before the decision was made.

Arguments for Retroactivity:

• Miller established a new rule that prohibits a specific type of punishment for a specific group of people (minors).

• Similar Eighth Amendment rulings have been applied retroactively in the past.

• It is unfair to continue to punish people under a rule that has been declared unconstitutional.

The Supreme Court has the authority to review the case because the Louisiana Supreme Court relied on federal law in its decision that Miller is not retroactive.

The Supreme Court should find that Miller is retroactive and apply it to all cases where minors were sentenced to life without parole. This would ensure that all individuals who were unconstitutionally punished have a chance at a fair sentence.

Summary of Argument

In 2012, the Supreme Court ruled in Miller v. Alabama that it's cruel and unusual to automatically sentence kids under 18 to life in prison without the possibility of parole. This means that kids who were given this sentence in the past should have their cases reviewed.

The Court said that kids are different from adults and deserve a chance at rehabilitation. They also said that the punishment of life without parole is too harsh for kids.

Some states have refused to apply this rule to kids who were already sentenced. They argue that it's not fair to change the rules after the fact.

However, the Supreme Court has said that when a punishment is found to be cruel and unusual, it must be stopped, even for people who were already sentenced. This is because it's a basic right to be protected from cruel and unusual punishment.

The Court is now considering whether to make the Miller rule retroactive, which would mean that all kids who were sentenced to life without parole would have their cases reviewed.

Summary of Argument

There's a law that says kids under 18 shouldn't automatically get life in jail without parole. This law is important because it's not fair to treat kids the same as adults when it comes to punishment.

Some people think this rule should only apply to new cases, but others believe it should also apply to kids who are already in jail. They say that it's not right to keep kids in jail for life without parole if they were under 18 when they did something wrong.

The highest court in the country can decide if this rule should apply to kids who are already in jail. They can do this because a court in Louisiana said that the rule doesn't apply to those kids.

Even if Louisiana said that their own state law doesn't allow the rule to apply, it's still important for the highest court to make sure that kids are treated fairly. They can't ignore the rule just because a state court doesn't want to follow it.