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Montgomery v. Louisiana (U.S. Sup. Ct.)
Montgomery v. Louisiana addressed whether the Supreme Court’s 2012 ruling in Miller v. Alabama, which held that sentencing schemes that mandate life without the possibility of parole for juveniles are unconstitutional under the Eighth Amendment, created a new substantive rule that applies retroactively to cases on collateral review.
In 1969, Henry Montgomery was sentenced to life imprisonment for murder. Even though Montgomery was 17 when he committed the offense for which he received the mandatory sentence of life in prison, the Louisiana state courts held that no relief was available now because the Supreme Court’s decision in Miller should not be applied retroactively to cases on collateral review. Louisiana had been one of a number of states where Miller was not applied retroactively, which meant that juvenile offenders whose cases were no longer subject to direct review could not challenge their sentence of mandatory life without parole, even though the Supreme Court held in Miller that such sentences violate the Eighth Amendment.
On July 28, 2015, CAC filed a friend-of-the-court brief in support of Montgomery on behalf of former juvenile court judges, arguing that retroactive application of Miller is the only way to vindicate the Court’s holding that mandatory life without parole sentences are inappropriate for juvenile offenders. As former juvenile court judges, amici have extensive experience interacting with and sentencing juvenile offenders, and know that juvenile offenders are generally less mature and more impressionable than adult offenders, making them at once “less culpable” for their offenses and also more amenable to change. For these reasons, amici believe that no juvenile should be sentenced to mandatory life without parole, and that the Court should apply its decision in Miller retroactively to cases currently on collateral review. As our brief demonstrated, Miller itself makes clear that many of the factors relevant to reviewing juvenile offenders’ sentences can and should be applied to cases on collateral review in the same way they would be applied to cases on direct review, and the criminal justice system is equipped to apply Miller in these retroactive situations even when significant time has passed since the offense.
The Court heard oral argument on October 13, 2015. On January 25, 2016, the Court held – by a 6-3 vote – that Miller’s prohibition on mandatory life without parole for juvenile offenders announced a new substantive rule that, under the Constitution, must be applied retroactively in cases on state collateral review. The Court reaffirmed Miller’s recognition that juveniles differ from adults in both their culpability and their possibility for reform, adding that “children who commit even heinous crimes are capable of change.” It also explained that remedying Miller violations would not impose an onerous burden on the states because states can apply the Court’s ruling by extending parole eligibility to juvenile offenders.