Evan Miller

  • June 25, 2012

    by Jeremy Leaming

    The Supreme Court provided a mixed response to Arizona’s harsh immigration law, which also included an odd take on state sovereignty by Justice Antonin Scalia in his concurring, dissenting opinion. The Court’s right-wing bloc also overturned Montana Supreme Court’s decision supporting common sense campaign finance regulation.

    So the high court’s most progressive action likely came in its 5-4 opinion, Miller v. Alabama. That opinion held that mandatory life sentences without parole of juveniles violates the Constitution’s ban on cruel and unusual punishment.

    Citing precedent set forth in the cases Roper v. Simmons and Graham v. Florida, Justice Elena Kagan, writing for the majority, reiterated that “children are constitutionally different from adults for purposes of sentencing. Because juveniles have diminished culpability and greater prospects for reform, we explained ‘they are less deserving of the most severe punishments.’”

    Children, Kagan, continued have different maturity levels than adults, they are more vulnerable to all kinds of pressures, and finally the child’s character is just not developed yet. Kagan noted the Court’s precedents “rested not only on common sense – on what ‘any parent knows’ – but on science and social science as well.”

  • March 13, 2012
    Guest Post

    By Kristin Henning, Sidley Austin-Robert D. McLean Visiting Clinical Professor of Law at Yale Law School and Professor of Law at Georgetown Law


    Seven years ago, in Roper v. Simmons, the U.S. Supreme Court recognized fundamental differences between children and adults that bear directly on the issue of culpability to outlaw imposition of the death penalty for any crime committed by a defendant younger than 18. Five years later, in Graham v. Florida, it relied on the same principles to ban life sentences without parole for juveniles convicted of non-homicide offenses.

    Next week, the Supreme Court will consider whether those principles must once again render a life-without-parole sentence unconstitutional for youth convicted of homicide offenses when it hears the cases of Kuntrell Jackson and Evan Miller, who were both sentenced to die in prison for crimes they committed when they were 14.  Because there is no scientific, legal or practical reason to disregard the findings in Roper and Graham, the established constitutional law must prevail and life-without-parole sentences for all teenagers, including Jackson and Miller, must be prohibited as excessive.

    Life imprisonment without parole, which discounts any possibility for rehabilitation, is a severe sentence for any offender. For a teenager, it is an extraordinary punishment in both length and psychological severity. And yet sentencing laws in many states make it possible for children to be locked away forever without any opportunity for release. 

    In most areas of the law, minors are treated with special solicitude and graduated responsibility. State laws prevent youths under 18 from voting, serving on juries or in the military, drinking alcohol, or marrying without parental consent. These protections are in place because teenagers are biologically and psychologically different than adults. Scientific research on adolescent development bolsters the commonsense understanding that teenagers lack self-control, are vulnerable to environmental pressures, and have fewer life experiences on which to draw in evaluating the consequences of their actions.