Law and Legal Systems
Mr. Payne
4/6/16
Case Brief Miller V Alabama
Miller v. Alabama 567 U.S (2012)
Judicial History: Miller signed a statement in which he stated that he had stolen Cannon’s money and driver’s license after a fight but he didn’t not set his trailer on fire. A jury trial found Miller guilty of capital murder in the course of arson and gave him the mandatory sentence of life without parole. Miller’s lawyers moved for a new trial and the Circuit Court’s denial of the motion. Miller then appealed to the Alabama Court of Criminal Appeals, challenging both the constitutionality of sentencing a 14-year-old to life without parole and the mandatory imposition of a life-without-parole sentence on a 14-year-old. The Alabama Court of Criminal Appeals held that Miller’s conviction was not …show more content…
unconstitutional, despite his age. Miller was denied a rehearing, as was his petition for certiorari to the Alabama Supreme Court. Miller sought a writ of certiorari from The Supreme Court of the United States and his request was granted.
Facts: Evan Miller was accused of beating, robbing, and murdering his neighbor Cole Cannon. Miller and Colby Smith, went to Cannon’s trailer searching of drugs. When Miller and Smith found none, they stole Cannon’s baseball cards and went back to Miller’s home. Later in the evening, Miller and Smith, went back to Cannon’s trailer. Cannon fell unconscious as a result of smoking and drinking, Miller then took $300 and Cannon’s driver’s license from Cannon’s wallet. When Miller was putting the wallet back in his pocket, he regained consciousness and attacked Miller. Smith hit Cannon with a bat, and Miller struck Cannon repeatedly with the bat and his fists. When they were finished they covered Cannon with a sheet and left his trailer. They later returned to Cannon’s trailer in an attempt to clean up the evidence, and decided to set fire to the trailer to conceal the crime while Cannon was still alive.
Issues:
1. This cases presents the issue of whether or not the courts sentencing of life in prison without parole to a 14-year-old to is cruel and unusual punishment.
2. Does a sentence of life without parole for a 14-year-old convicted of murder violate the Eighth Amendment’s prohibition against cruel and unusual punishments?
Rules:
Eighth Amendment- “No cruel or unusual punishment”
Roper v. Simmons (2005)- the court held that it is unconstitutional to impose capital punishment for crimes committed while under the age of 18
Graham v. Florida (2010)- the court held that juvenile offenders cannot be sentenced to life imprisonment without parole for non-homicide offenses
Analysis: The parties mostly differ about whether sentencing a 14-year-old to life in prison without the chance for further appeal disregards the Eighth Amendment.
The parties’ debate focuses on varying interpretations of the Supreme Court cases of Roper v. Simmons and Graham v. Florida. Roper held that minors can't be sentenced to capital punishment. Graham held that minors can't be sentenced to life in jail without the chance for further appeal for non-crime offenses. Miller stated that both Roper and Graham held that cruel sentences connected to minors violated the Eighth Amendment; Miller contends that these cases remain for the suggestion that adolescents should receive different treatment than adults in sentencing, and that a mandatory life-without-parole without-any chance to appeal sentence for a 14-year-old is precisely the sort of sentence Roper and Graham forbid. Alabama contends that Roper and Graham remain for the proposition that Eighth Amendment jurisprudence should be predicated on widely accepted sentencing practices, and that a life-without-parole sentence for a 14-year-old with national standards and developing guidelines of
decency.
Conclusion: By requiring that all children convicted of homicide receive life in prison without possibility of parole, regardless of their age or age-related characteristics or the nature of their crimes, the mandatory sentencing systems violate the Eighth Amendment’s ban on cruel and unusual punishment. The court reverses the judgments of the Arkansas Supreme Court and Alabama Court of Criminal Appeals.