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Miller v. Alabama and Jackson v. Hobbs

The decision prohibited mandatory life without parole for juvenile homicide offenders, allowing the sentence only in rare cases after consideration of a teen’s circumstances and potential for change.


In 2003, Evan Miller, 14, was at home with a friend in Moulton, Alabama, when a neighbor, Cole Cannon, came by to make a drug deal with Miller’s mother, according to court records. The teens followed Cannon to his trailer. After all three smoked marijuana and drank, Cannon passed out and Miller robbed him. Cannon awoke and grabbed Miller, whose friend struck the man with a baseball bat. Miller then repeatedly beat Cannon, first with his fists, then with the bat, placing a sheet over the man’s head and shouting: “I am God. I’ve come to take your life.” The two boys set Cannon’s trailer on fire, and Cannon died of smoke inhalation and his injuries. Miller’s life-without-parole sentence was the latest chapter in a chaotic childhood. He had an alcoholic, drug-addicted mother and an abusive stepfather, had been in and out of foster care and had attempted suicide four times, according to court records.

In the other case, Kuntrell Jackson also was 14 when he and two other teens set out to rob a video store in Blytheville, Arkansas. One of Jackson’s companions pulled a sawed-off shotgun from his jacket and fatally shot store clerk Laurie Troup. The teens fled without any money. Jackson, who had a juvenile record of car theft and shoplifting, was tried as an adult for the 1999 crime, convicted of murder and aggravated robbery, and sentenced to life without parole.


In a 5-4 vote, the Supreme Court in 2012 said mandatory life without parole for juvenile homicide offenders was unconstitutional, amounting to cruel and unusual punishment. “In neither case did the sentencing authority have any discretion to impose a different punishment,” Justice Elena Kagan wrote. “State law mandated that each juvenile die in prison even if a judge or jury would have thought that his youth and its attendant characteristics, along with the nature of his crime, made a lesser sentence ... more appropriate. Such a scheme prevents those meting out punishment from considering a juvenile’s `lessened culpability’ and greater `capacity for change’ ... and runs afoul of our cases’ requirement of individualized sentencing for defendants facing the most serious penalties.”

At a resentencing hearing in March, Miller’s lawyers cited his abusive upbringing and argued that at 14, his brain wasn’t fully developed. The state argued Miller should remain behind bars the rest of his life. Under an Alabama law adopted last year, a judge can either resentence Miller to life without parole or he can become eligible for parole after serving 30 years. A decision is pending.

An Arkansas judge resentenced Jackson to 20 years in prison. Disciplinary violations made him ineligible to come before the state parole board until last year, and his first request for release was denied. Jackson again went before the board in February. He was granted parole and conditionally released.


Roper v. Simmons

This decision banned the death penalty for those under the age of 18. Prior to the ruling, 16 and 17 year olds were eligible for capital punishment in some states.

Graham v. Florida

The decision prohibited life-without-parole sentences for juveniles in cases that did not involve murder.

Miller v. Alabama and Jackson v. Hobbs

The decision prohibited mandatory life without parole for juvenile homicide offenders, allowing the sentence only in rare cases after consideration of a teen’s circumstances and potential for change.

Montgomery v. Louisiana

The decision made clear that the ban on mandatory life without parole in juvenile homicide cases applied retroactively, giving more than 2,000 inmates a chance for reconsideration.


Decades ago in the tough-on-crime ‘80s and ‘90s, many states — stoked by fears of teen “superpredators” — enacted laws to punish juvenile criminals like adults. The U.S. became an international outlier, sentencing offenders under 18 to live out their lives in prison for homicide and, sometimes, rape, kidnapping, armed robbery.

There has since been a shift. Five years ago, the U.S. Supreme Court banned mandatory life without parole for juveniles in murder cases. Then last year, the court went further, saying the more than 2,000 already serving such sentences must get an opportunity chance to show their crimes did not reflect “irreparable corruption” and, if not, have some hope for freedom.

The January 2016 ruling set the stage for an unprecedented second look at hundreds and hundreds of cases, some many decades old now, in courtrooms across America. The Associated Press leveraged its reporting power in all 50 states to examine how judges and prosecutors, lawmakers and parole boards are now revisiting juvenile lifer cases. Many have been resentenced and released, with more hearings continuing in the days, weeks and months ahead. But in some states, officials have delayed review of cases or fought to keep the vast majority of their affected inmates locked up for life.

View series View all 50 states