Montgomery v. Louisiana

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Criminal Law
  • Date Filed: January 25, 2016
  • Case #: 14-280
  • Judge(s)/Court Below: KENNEDY, J., delivered the opinion of the Court, in which ROBERTS, C. J., and GINSBURG, BREYER, SOTOMAYOR, and KAGAN, JJ., joined. SCALIA, J., filed a dissenting opinion, in which THOMAS and ALITO, JJ., joined. THOMAS, J., filed a dissenting opinion.
  • Full Text Opinion

Juveniles who were sentenced to life without parole before the decision in Miller can petition for parole if they were not allowed to present mitigation evidence during sentencing.

Petitioner was convicted of murder without capital punishment when he was a juvenile. Under the Louisiana statute, a sentence of life without parole was automatic. The Court decided in Miller v. Alabama that courts cannot sentence a juvenile to life without parole without first applying principles of juvenile sentencing, which includes mitigating factors. Petitioner argues that the decision in Miller should be retroactive and apply to his case and his sentence is a violation of the Eighth Amendment. The Supreme Court of Louisiana denied Petitioner on the grounds that the decision in Miller was procedural and the states did not have to follow the ruling.

The Supreme Court determined that the decision in Miller affected a substantive area of constitutional law and should be applied retroactively. The Court determined this was not a burden on states because rather than retry each case, the states could simply allow those convicted to petition for parole.

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