MILLER v. ALABAMA

Facts: On July 15, 2003 Evan Miller who was 14 years old, was at home when Cole Cannon a drug dealer, came to Miller’s house to make a drug deal with Millers mom. After the drug deal Miller and his friend Colby Smith went to Cannons house where they smoked weed and played drinking games. After Cannon passed out Miller stole his wallet and took 300$ splitting it with Smith. When Miller tried to put the wallet back Cannon woke up and grabbed him by the throat, Smith grabbed a baseball bat and hit Cannon with it until he released Miller, and then Miller grabbed the bat and started hitting Cannon in the head. Miller placed a sheet over Cannons head and stated “I am God, I’ve come to take your life,’ before hitting Cannon one last time and then returning to his own trailer with smith. The two boys Smith and Miller then came back to Cannons trailer deciding to cover up evidence and set two fires. Cannon eventually died from smoke inhalation and his injuries from the beating.
The state charged Miller as an adult with murder in the course of arson. Which carries a mandatory minimum punishment of life without parole. Miller argued that he was only 14 and not an adult so being sentenced to life without parole was a cruel and unusual punishment and unconstitutional under the 8th and 14th amendments.

Issue:Is sentencing a 14 year old boy to life without parole a cruel and unusual punishment

Rule:The eighth amendment restricts the severity of punishments that state and federal governments may impose upon persons who have been convicted of a criminal offense The fourteenth amendment prohibits a state from violating the due process rights of a citizen.

Analysis:the Court suggests that any sentencing proceeding that allowed defendants to draw attention to their age and age-related characteristics and the nature of their crimes might be sufficient but the Court cites precedents in the death penalty context that have formalized guidelines for the sentencing hearings necessary to fully ventilate mitigating conditions so they will leave it for the lower courts to decide.

Conclusion:The Supreme Court ruled that that mandatory life without parole for those under age of 18 at the time of their crime violates the 8th amendment’s prohibition on cruel and unusual punishment and remanded the case back to trial courts for resentencing.