The Eighth Amendment prohibits a mandatory life without parole sentencing scheme for juvenile homicide offenders. In both Jackson v. Hobbs (10-9647) and Miller v. Alabama (10-9646), the 14-year-old juveniles were tried as adults, convicted of murder and, under mandatory sentencing schemes, sentenced to LWOP. Reversed and remanded. For sentencing purposes, children are constitutionally different from adults and the distinct attributes of the juvenile offender lessen the justification for imposing the harshest of penalties even for terrible crimes. But the mandatory LWOP scheme fails to acknowledge these factors by not considering the unique nature of the juvenile in determining the sentence to be imposed. Additionally, although the LWOP scheme shares characteristics with a death penalty scheme, it lacks the death penalty scheme’s individualized sentencing by failing to consider the mitigating factor of youth. For these reasons, mandatory LWOP sentencing violates the Eight Amendment’s ban against cruel and unusual punishment and cannot stand.
Case Summaries