Miller v. Alabama held that mandatory life without parole for juvenile offenders is unconstitutional.
In 2012, the Supreme Court ruled 5–4 that sentencing laws must allow a judge or jury to consider a juvenile’s age and related circumstances before imposing life without parole for homicide. The consolidated cases involved Evan Miller in Alabama and Kuntrell Jackson in Arkansas.
The decision did not create an absolute ban on life without parole for every juvenile offender. Instead, it rejected mandatory schemes that treated children like adults and prevented individualized sentencing. Factors such as immaturity, family background, peer pressure, and the possibility of rehabilitation must be considered.
A common mix-up is Graham v. Florida, which barred life without parole for juveniles convicted of non-homicide offenses. Roper v. Simmons addressed the death penalty for juvenile offenders. Later, Montgomery v. Louisiana made Miller’s rule retroactive to cases already final.