Juvenile Sentencing after Miller
State and Lower-Court Reaction
In Miller v. Alabama (2012), the U.S. Supreme Court held that the Eighth Amendment prohibits courts from automatically imposing life without parole (LWOP) sentences on offenders who committed homicides while they were juveniles (under age 18). The Court did not categorically bar these sentences but stated that a court must “take into account how children are different, and how those differences counsel against irrevocably sentencing them to a lifetime in prison.” Miller followed the Court’s 2010 ruling in Graham v. Florida (2010), where it held that the Eighth Amendment prohibits States from imposing LWOP on juvenile defendants for non-homicide crimes….
