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Required life sentences for juveniles outlawed by Supreme Court
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The Supreme Court on Monday struck down mandatory life sentences for juveniles, a landmark decision that will force Pennsylvania to rewrite its sentencing laws and may lead courts to revisit the cases of hundreds of inmates currently serving life sentences for crimes they committed before they turned 18.
In Pennsylvania, an estimated 470 inmates fall into that category, more than any state in the nation, according to the Juvenile Law Center in Philadelphia. In Allegheny County, 11 defendants arrested as juveniles await trial on homicide charges where convictions previously would have netted mandatory life sentences.
The high court ruled 5-4 in Miller v. Alabama that imposing mandatory life sentencing on defendants convicted of crimes they committed before their 18th birthday constitutes "cruel and unusual punishment," a violation of the Eighth Amendment.
"Such mandatory penalties, by their nature, preclude a sentencer from taking account of an offender's age and the wealth of characteristics and circumstances attendant to it," Justice Elena Kagan wrote in the majority opinion. "Under these schemes, every juvenile will receive the same sentence as every other -- the 17-year-old and the 14-year-old, the shooter and the accomplice, the child from a stable household and the child from a chaotic and abusive one."
The decision fell short of declaring all life sentences for juveniles unconstitutional. Instead, the ruling means that juvenile defendants no longer can be automatically sentenced to life without the possibility of parole. It will force the state to refashion rules that mandate life sentences for anyone convicted of first- or second-degree murder, no matter their age.
Marsha Levick, deputy director of the Juvenile Law Center, called the decision "a watershed case in criminal procedure."
"These kids can no longer be required to serve life sentences," she said. "They will have to be given the opportunity for individualized sentencing for a judge to determine what the best sentence will be."
In Miller v. Alabama, the court overturned life sentences for two men convicted of crimes they committed as 14-year-olds. In 2003 in Alabama, Evan Miller beat a neighbor and then set fire to his trailer to cover the evidence, killing him. Four years earlier in Arkansas, Kuntrell Jackson was arrested on a felony murder charge for serving as the lookout in a botched robbery in which his friend shot and killed a video store clerk.
Writing for the majority, Justice Kagan said an individual's upbringing should weigh heavily in a judge's consideration of how a juvenile should be sentenced, as should a growing body of evidence that suggests that children have different brain chemistry than adults.
"Mandatory life without parole for a juvenile precludes consideration of his chronological age and its hallmark features -- among them, immaturity, impetuosity, and failure to appreciate risks and consequences," she wrote. "It prevents taking into account the family and home environment that surrounds him -- and from which he cannot usually extricate himself -- no matter how brutal or dysfunctional. It neglects the circumstances of the homicide offense, including the extent of his participation in the conduct and the way familial and peer pressures may have affected him."
Justice Kagan did not outline when she believed a life sentence should be imposed on a juvenile defendant but wrote that "we think appropriate occasions for sentencing juveniles to this harshest possible penalty will be uncommon."
In Pennsylvania, the decision means that judges will be free to impose lesser sentences on juvenile defendants convicted of first- or second-degree murder, weighing factors such as their family and background and the nature of the case.
It is unclear if the case will apply retroactively, but if it does, inmates serving life sentences for crimes they committed as juveniles may be entitled to have a judge review their case, giving them the opportunity for parole and early release.
Allegheny County Common Pleas Judge David Cashman said he is opposed to all mandatory sentences.
"I've never liked mandatory sentences because I don't think a mandatory sentence applies to all the parties," he said. "People are unique."
He has overseen five cases in which defendants received life sentences for crimes they committed as juveniles, but he said given the opportunity, he likely would not have given them a lesser sentence.
"That type of sentence is justified ... the cases were truly intentional, malicious and willful premeditated murders," he said.
Allegheny County District Attorney Stephen A. Zappala Jr. said in a statement that the ruling "comes at a time when law enforcement is seeing an ever increasing number of guns ending up in juvenile hands, often resulting in juveniles engaging in violent behavior."
"That being said, this office has the obligation of protecting the interests of all who encounter the criminal justice system, including offenders. This office will abide by the direction set forth by today's decision and by any changes to the law that the Pennsylvania General Assembly deems necessary. As far as how individual cases affected by today's decision will be reviewed, our office will be working closely with the courts and with the defense bar to determine those procedures."
First Published June 26, 2012 12:00 am
