Case summary
In Miller v. Alabama, 132 S. Ct. 2455 (2012), the Supreme Court ruled that sentencing a juvenile to life imprisonment without the probability of parole was unconstitutional. Evan Miller and Colby Smith assaulted a neighbor and set his trailer on fire. Arson resulted in the death of the neighbor. The Alabama court charged Miller with murder as a juvenile, before transferring him to the adult court. According to Alabama law, a guilty verdict would have resulted in life imprisonment without the probability of parole. The jury found Miller guilty and condemned him to life imprisonment without the probability of parole. Miller challenged the constitutionality of the ruling (Chemerinsky, 2012).
Facts
In 2003, as a 14-year boy, Miller assaulted and robbed his neighbor, Cole Cannon, after he had visited Miller’s home. While Cannon was in Miller’s home, Miller and Colby Smith, a friend, stole his baseball cards from his trailer. Later, Miller and Smith found Cannon lying unconscious in his trailer due to drinking and smoking. Miller stole $300 and a driver’s license from Cannon’s wallet. Thereafter, there was a confrontation between Miller and Cannon, after Cannon regained consciousness and found Miller with his wallet. During the confrontation, Smith and Miller hit Cannon until he lost consciousness. Thereafter, the co-defendants fled the scene of the incident. They returned later and tried to clear out the blood from the scene. Finally, they decided to set the trailer on fire to conceal their crime (Chemerinsky, 2012). While they were setting the trailer on fire, Cannon was still in the trailer. Therefore, the co-defendants had a guilty mind (men’s rea) before committing the guilty action (actus reus). They had a guilty mind after physically assaulting Cannon. This is the main reason that made them attempt to conceal their crime. However, in the course of concealing the crime, they committed another crime. Therefore, there was temporal concurrence as actus reus and men’s rea occurred simultaneously (Emanuel, 2007).
Issue
Was the Alabama court right in sentencing a juvenile to life imprisonment without the likelihood of parole?
Holding
The jury ruled that the life imprisonment verdict violates the Eighth and Fourteenth Amendments, which protect offenders from cruel and unusual punishments.
Opinion
Juveniles’ immaturity and failure to comprehend the repercussions of their actions were the key factors that made the jury term the sentence as cruel and unusual. In addition, the jury ruled that juveniles do not control their social environment, which may make them commit crimes. Therefore, the Alabama court passed a wrong judgment in the trial. In addition, the Alabama court was harsh in its judgment since Miller was the first offender. However, the ruling of this case does not prohibit juveniles from receiving life sentences. The ruling ensures that judges should take into consideration the nature of the crime and the defendant’s social environment before sentencing a juvenile to life imprisonment without the likelihood of parole (Chemerinsky, 2012). The court can still sentence repeated juvenile offenders to life imprisonment.
Discussion
The Eighth and Fourteenth Amendments of the US constitution prohibit courts from giving cruel and unusual punishments to offenders. In Miller v. Alabama, the petitioner claimed that sentencing him to life imprisonment without the possibility of parole violates his constitutional rights, which protect him from facing cruel and unusual punishments (Shahidullah, 2008). However, the Alabama prosecution supported the sentence of life imprisonment without the probability of parole. The state of Alabama argued that the sentence was suitable according to the severity of the offense.
In a murder trial, the burden of proof lies with the prosecution. The prosecution must convince the jury that the defendant committed the crime. In addition, the prosecution must prove that the defendants committed the offense willfully and were conscious of their actions. Insanity, intoxication, and infancy are some of the most common grounds for dismissal of murder trials. The above factors imply that the defendant did not understand the repercussion of their actions while committing the crime (Stephens & Scheb, 2007).
A juvenile’s brain is not fully developed. Therefore, the juvenile may not know the repercussions of their actions. Underdevelopment of juveniles’ brains increases the probability of juveniles engaging in risky activities. This is due to their inability to make correct judgments. The neurological development of juveniles makes actus reus and men’s rea have little significance in the case. The guilty mind (men’s rea) may motivate a juvenile to commit a guilty action (actus reus). Thus, a juvenile may use infancy as the defense against a criminal conviction.
Conclusion
Insanity, infancy, intoxication, incompetency, and procedural issues are the main issues that a defendant may use in the defense. The above factors may render actus reus and men’s rea invalid. In Miller v. Alabama, the petitioner used infancy successfully in overturning his sentence. The jury ruled that it was unconstitutional for the previous court to sentence the petitioner to life imprisonment without the possibility of parole. In the future, defense attorneys may use Miller v. Alabama in challenging the constitutionality of life imprisonment of juveniles.
References
Chemerinsky, E. (2012). It’s now the John Roberts court. The Green Bag, Vol.14, No.4. Pp. 2002-2059.
Emanuel, S.L. (2007). Criminal law. New York: Aspen Publishers.
Shahidullah, S.M. (2008). Crime policy in America: Laws, institutions, and programs. Lanham, MD: University Press of America.
Stephens, O.H. & Scheb, J.M. (2007). American constitutional law: Civil rights and liberties. Belmont, CA: Cengage Learning.