December 18, 2014

The U.S. Supreme Court’s Next Juvenile Sentencing Case

In recent years, the U.S. Supreme Court has issued a number of rulings on the constitutionality of sentences for juvenile offenders.  Most recently, in 2012, the Court ruled that the Eighth Amendment prohibits automatically imposing a sentence of life without parole on offenders who committed homicides while under age 18. While the Court did not prohibit these sentences in all circumstances, it required courts to consider how juveniles are different from adults and how that counsels against a life sentence without parole (Miller v. Alabama, 132 S.Ct. 2455).

In Miller, the Court did not say whether its ruling applied retroactively to inmates sentenced before the Court issued its ruling.  After a number of state supreme courts reached opposite conclusions on this question, the U.S. Supreme Court agreed to decide the issue.  In Toca v. Louisiana, the Court will consider whether someone automatically sentenced to life in prison without parole for a crime committed while a juvenile is entitled to a new sentencing hearing.

The Court granted permission to hear the case on December 12th.  A ruling is likely before the Court’s term ends next June.

Read more about the case in the New York Times.

Read OLR reports on juvenile sentencing:
  • 2014-R-0108, Juvenile Sentencing Laws and Court Decisions After Miller v. Alabama
  • 2012-R-0290, Summary of U.S. Supreme Court Case on Mandatory Life Sentences Without Parole for Juvenile Homicide Convictions
  • 2012-R-0045, Summary of U.S. Supreme Court Case on Life Sentences Without Parole for Juvenile Nonhomicide Convictions