SUPREME COURT RULES MANDATORY LIFE SENTENCES FOR JUVENILE HOMICIDE OFFENDERS IS UNCONSTITUTIONAL
Prior to June 2012, many states, including Pennsylvania, had laws that required that all persons, including juveniles, convicted of first-degree murder be sentenced to life imprisonment without the possibility of parole. For instance, prior to June 2012, in Pennsylvania, all persons, even juveniles, convicted of first or second-degree murder received an automatic mandatory life sentence without the possibility of parole.
On June 25, 2012, in a watershed case, the United States Supreme Court ruled that mandatory sentences of life without the possibility of parole for juvenile homicide offenders violates the Eight Amendment of the United States Constitution. See Miller v. Alabama, 132 S. Ct. 2455 (2012).
In Miller, Justice Egan, writing for a majority of the Court, noted that the Eight Amendment’s prohibition of cruel and unusual punishment guarantees individuals the right not to be subjected to excessive sanctions. Furthermore, the Court opined that ‘that right, flows from the basic precept of justice that punishment for crime should be graduated and proportioned’ to both the offender and the offense’.
In deciding that juvenile homicide offenders should be treated differently than their adult counterparts, the Court relied heavily on the fact that developments in psychology and brain science continue to show fundamental differences between juvenile and adult minds-for example, in parts of the brain involved in behavior control.
Moreover, the Supreme Court relied on three significant gaps between juveniles and adults as justification for treating juvenile homicide offenders differently than adults similarly situated. First, children have a lack of maturity and an underdeveloped sense of responsibility…leading to recklessness, impulsivity, and heedless risk-taking. Second, children are more vulnerable to negative influences and outside pressures, including from their family and peers; they have limited control over their own environment and lack the ability to extricate themselves from horrific, crime-producing settings. And third, a child’s character is not as well formed as an adult’s; his traits are less fixed and his actions less likely to be evidence of irretrievable depravity.
It is worth noting that Miller does not prohibit a court from handing down a life sentence to a juvenile homicide offender. Rather, the Miller decision requires that sentencing alternatives to life imprisonment be made available for juvenile homicide offenders and, Miller also requires that sentencing courts take into consideration the age and maturity of juvenile homicide offenders. However, if after taking into consideration a juvenile offender’s age and maturity, a sentencing court is still convinced that a life sentence is warranted such a sentence is still permissible.
In response to Miller, Pennsylvania transformed its sentencing scheme for juvenile homicide offenders allowing sentencing judges the option to sentence a juvenile 15 years or older convicted of first degree murder to a 35 year minimum sentence, and juveniles under 15 years old at the time of a homicide to a 25 year minimum sentence.
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