A 2012 decision from the U.S. Supreme Court on juvenile life sentences is creating confusion in the Eighth Circuit and beyond.
Last month, the Iowa Supreme Court concluded that the U.S. Supreme Court's ruling in Miller v. Alabama -- which outlawed mandatory life-without-parole sentences for juveniles -- should be applied retroactively, rather than only to future cases.
But the Minnesota Supreme Court and a number of other courts have reached the opposite conclusion. With inmates, their lawyers, lawmakers and sentencing-policy advocates in legal limbo, the Eighth Circuit Court of Appeals may weigh in on the matter.
Miller v. Alabama
In a 5-4 split with Justice Elena Kagan writing for the majority, the Court ruled that mandatory life-without-parole sentences for people under 18 constituted cruel and unusual punishment in violation of the Eighth Amendment.
Judges must take into account "the mitigating qualities of youth" when sentencing juveniles -- even those convicted for serious and violent crimes. Specifically, the mitigating circumstances that must be taken into account include the offender's age, childhood, life experience, degree of responsibility the youth was capable of exercising, and the chances for rehabilitation.
Substantive v. Procedure
Courts have split over the nature of the Supreme Court's decision -- namely, whether the opinion is substantive or procedural in nature. Albeit a technical question, the implications are serious. A substantive rule would apply retroactively, whereas a procedural rule would not.
It's becoming increasingly clear that states are struggling with how to apply the Court's decision -- and states within the Eighth Circuit are no exception.
Minnesota Supreme Court
Timothy Patrick Chambers, who killed a police officer when he was 17, challenged his life-without-parole sentence after the Miller ruling. But the Minnesota Supreme Court rejected his appeal on the grounds that the Court's decision was not a substantive ban on such sentences, but a procedural change.
Iowa Supreme Court
In contrast, the Iowa Supreme Court applied the opinion retroactively. In fact, the court took the Miller ruling one step further and ordered two juvenile cases for resentencing that didn't involve mandatory life terms, reports the Des Moines Register.
The court said the sentences were the "practical equivalent" of a mandatory life sentence.
The line of cases on this matter has sharply divided the court. Justice Edward Mansfield is concerned the court's broad interpretation of the Miller decision could produce a "flurry" of court hearings, according to the Register.
The Eighth Circuit Court of Appeals may very well step into the fray and lend some guidance on how best to interpret Miller -- scores of inmates and their lawyers are surely counting it.
- Courts Split Over Ruling on Juvenile Life Sentences (The Wall Street Journal)
- Graham Applies Retroactively; No Life Without Parole for Juvies (FindLaw's Ninth Circuit Blog)
- Eighth Amendment Prohibits Sentencing Juveniles to Life without Parole for Non-Homicide Crimes (FindLaw's Supreme Court Blog)