Jones v. Mississippi
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Summary

SCOTUS allows life without parole for juvenile murderers (Jones v. Mississippi, 2021). No separate finding of permanent incorrigibility required; judges have flexibility in sentencing but must consider youth.

2021 | Federal Juristiction

Jones v. Mississippi

Keywords juvenile LWOP; life without parole; juvenile offenders; Miller v. Alabama; mandatory sentencing; Eighth Amendment (U.S.); cruel and unusual punishment; Mississippi Supreme Court; permanent incorrigibility; U.S. Supreme Court

Abstract

Brett Jones, convicted of murder at 15, challenged his life-without-parole sentence after the Supreme Court's rulings in Miller v. Alabama and Montgomery v. Louisiana. These cases limited juvenile life sentences but left open whether a separate finding of permanent incorrigibility was required. The Mississippi Supreme Court had ordered Jones' resentencing, but he again received life without parole. The Supreme Court, in a 6-3 decision with Justice Kavanaugh writing for the majority, ruled against Jones. They determined the Eighth Amendment did not mandate a separate finding of permanent incorrigibility. The majority argued that Miller allowed for discretionary sentencing systems, where the judge considers the offender's age alongside other factors. Justice Sotomayor dissented, arguing that Miller required a more individualized assessment to ensure the sentence was not cruel and unusual punishment for a juvenile offender.

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Abstract

Brett Jones, convicted of murder at 15, challenged his life-without-parole sentence after the Supreme Court's rulings in Miller v. Alabama and Montgomery v. Louisiana. These cases limited juvenile life sentences but left open whether a separate finding of permanent incorrigibility was required. The Mississippi Supreme Court had ordered Jones' resentencing, but he again received life without parole. The Supreme Court, in a 6-3 decision with Justice Kavanaugh writing for the majority, ruled against Jones. They determined the Eighth Amendment did not mandate a separate finding of permanent incorrigibility. The majority argued that Miller allowed for discretionary sentencing systems, where the judge considers the offender's age alongside other factors. Justice Sotomayor dissented, arguing that Miller required a more individualized assessment to ensure the sentence was not cruel and unusual punishment for a juvenile offender.

In the case of Jones v. Mississippi, the Supreme Court considered the constitutionality of a life-without-parole (LWOP) sentence imposed on Brett Jones, who was convicted of murder at age 15. Jones's sentence was challenged following the Court's decisions in Miller v. Alabama (2012) and Montgomery v. Louisiana (2016), which placed limitations on the use of mandatory LWOP sentences for juveniles but left unresolved the question of whether a separate judicial finding of permanent incorrigibility was required. The Mississippi Supreme Court subsequently ordered Jones to be resentenced, but he was again sentenced to LWOP.

The Supreme Court, in a 6-3 decision authored by Justice Kavanaugh, reversed the Mississippi Supreme Court's ruling. The majority opinion held that the Eighth Amendment's prohibition against cruel and unusual punishment does not mandate a separate finding of permanent incorrigibility before a juvenile can be sentenced to LWOP. The Court reasoned that Miller permits discretionary sentencing schemes where a sentencing judge considers the mitigating factor of the offender's youth alongside other relevant factors. Justice Sotomayor authored the dissenting opinion, joined by Justices Breyer and Kagan, arguing that Miller necessitates a more individualized assessment of a juvenile offender's potential for rehabilitation to ensure that an LWOP sentence is not disproportionate to the crime and therefore unconstitutional.

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Abstract

Brett Jones, convicted of murder at 15, challenged his life-without-parole sentence after the Supreme Court's rulings in Miller v. Alabama and Montgomery v. Louisiana. These cases limited juvenile life sentences but left open whether a separate finding of permanent incorrigibility was required. The Mississippi Supreme Court had ordered Jones' resentencing, but he again received life without parole. The Supreme Court, in a 6-3 decision with Justice Kavanaugh writing for the majority, ruled against Jones. They determined the Eighth Amendment did not mandate a separate finding of permanent incorrigibility. The majority argued that Miller allowed for discretionary sentencing systems, where the judge considers the offender's age alongside other factors. Justice Sotomayor dissented, arguing that Miller required a more individualized assessment to ensure the sentence was not cruel and unusual punishment for a juvenile offender.

Brett Jones, who received a life sentence without parole for a murder committed at age 15, challenged his sentence following landmark Supreme Court decisions in Miller v. Alabama and Montgomery v. Louisiana. These cases established limitations on juvenile life sentences but left unresolved whether judges must make a separate determination of permanent incorrigibility before imposing such a sentence. Jones' case was remanded to the Mississippi Supreme Court for resentencing, but he was again sentenced to life without the possibility of parole.

In a 6-3 decision authored by Justice Kavanaugh, the Supreme Court ruled against Jones, finding that the Eighth Amendment does not require a separate judicial finding of permanent incorrigibility. The majority opinion held that Miller permits discretionary sentencing systems where a judge considers the offender's youth alongside other relevant factors. Justice Sotomayor penned a dissenting opinion, arguing that Miller necessitates a more individualized assessment of juvenile offenders to ensure the sentence is not unconstitutionally cruel and unusual.

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Abstract

Brett Jones, convicted of murder at 15, challenged his life-without-parole sentence after the Supreme Court's rulings in Miller v. Alabama and Montgomery v. Louisiana. These cases limited juvenile life sentences but left open whether a separate finding of permanent incorrigibility was required. The Mississippi Supreme Court had ordered Jones' resentencing, but he again received life without parole. The Supreme Court, in a 6-3 decision with Justice Kavanaugh writing for the majority, ruled against Jones. They determined the Eighth Amendment did not mandate a separate finding of permanent incorrigibility. The majority argued that Miller allowed for discretionary sentencing systems, where the judge considers the offender's age alongside other factors. Justice Sotomayor dissented, arguing that Miller required a more individualized assessment to ensure the sentence was not cruel and unusual punishment for a juvenile offender.

Brett Jones, who was found guilty of murder at age 15, tried to get his life sentence without parole changed. He did this after the Supreme Court made decisions in two cases, Miller v. Alabama and Montgomery v. Louisiana. These decisions said that judges cannot automatically give kids life in prison without a chance of parole but did not clearly say if judges had to also decide if the person could ever change for the better.

The Mississippi Supreme Court initially agreed that Jones should be sentenced again. However, the judge gave him the same sentence: life without parole. Jones appealed this decision to the Supreme Court.

In a 6-3 vote, the Supreme Court, with Justice Kavanaugh writing the main decision, said Jones' sentence should stand. They decided that the Constitution does not force judges to specifically decide if a young person can be rehabilitated. The majority explained that the earlier Miller decision let judges consider the person's age along with other things during sentencing. Justice Sotomayor disagreed, writing that Miller required a closer look at each person to make sure the punishment wasn't too harsh for someone who committed a crime as a teenager.

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Abstract

Brett Jones, convicted of murder at 15, challenged his life-without-parole sentence after the Supreme Court's rulings in Miller v. Alabama and Montgomery v. Louisiana. These cases limited juvenile life sentences but left open whether a separate finding of permanent incorrigibility was required. The Mississippi Supreme Court had ordered Jones' resentencing, but he again received life without parole. The Supreme Court, in a 6-3 decision with Justice Kavanaugh writing for the majority, ruled against Jones. They determined the Eighth Amendment did not mandate a separate finding of permanent incorrigibility. The majority argued that Miller allowed for discretionary sentencing systems, where the judge considers the offender's age alongside other factors. Justice Sotomayor dissented, arguing that Miller required a more individualized assessment to ensure the sentence was not cruel and unusual punishment for a juvenile offender.

A teenager named Brett Jones was found guilty of murder when he was only 15 years old. He was sentenced to life in prison, with no chance of ever being released. Jones argued that this punishment was too harsh because important court decisions had recently been made, which said judges should be extra careful before giving such a long sentence to someone so young when they committed the crime.

The Supreme Court reviewed Jones' case. In a close vote, 6 judges against 3, they decided to keep Jones' sentence the same. The judge who explained the court's decision said the Constitution doesn't require judges to make a separate choice about whether a young person can ever improve. They can consider the person's age along with other details about the crime. However, 3 other judges disagreed. They believed judges should carefully examine each young person's situation to make sure the punishment is fair and not too harsh.

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Footnotes and Citation

Cite

Jones v. Mississippi, 593 U.S. 98 (2021)

Highlights