Supreme Court strikes down mandatory life without parole for minor defendants

Be happy this happened. In a landmark decision today, the Supreme Court of the United States has declared it unconstitutional under the Cruel and Unusual Punishments Clause to have mandatory life-without-parole punishments for defendants who were minors at the time of the offense. The decision flows naturally from its decision two years ago that minors could not be incarcerated for life for non-homicide offenses, and continues this Court's active jurisprudence in employing the Eighth Amendment against the harshest of penalties. As Justice Kagan summarizes for the Court:

Mandatory life without parole for a juvenile precludes consideration of his chronological age and its hallmark features'among them, immaturity, impetuosity, and failure to appreciate risks and consequences. It prevents taking into account the family and home environment that surrounds him'and from which he cannot usually extricate himself'no matter how brutal or dysfunctional. It neglects the circumstances of the homicide offense, including the extent of his participation in the conduct and the way familial and peer pressures may have affected him. Indeed, it ignores that he might have been charged and convicted of a lesser offense if not for incompetencies associated with youth'for example, his inability to deal with police officers or prosecutors (including on a plea agreement) or his incapacity to assist his own attorneys. See, e.g., Graham, 560 U. S., at _ (slip op., at 27) ('[T]he features that distinguish juveniles from adults also put them at a significant disadvantage in criminal proceedings'); J. D. B. v. North Carolina, 564 U. S. _, _ (2011) (slip op., at 5'6) (discussing children's responses to interrogation). And finally, this mandatory punishment disregards the possibility of rehabilitation even when the circumstances most suggest it.

The opinion of the Court is here, and the five-justice majority is written by Justice Kagan, with the three liberals and Kennedy joining, and she stresses how well this fits within the Court's recent history.

The cases before us implicate two strands of precedent reflecting our concern with proportionate punishment. The first has adopted categorical bans on sentencing practices based on mismatches between the culpability of a class of offenders and the severity of a penalty. So, for example, we have held that imposing the death penalty for nonhomicide crimes against individuals, or imposing it on mentally retarded defendants, violates the Eighth Amendment. Several of the cases in this group have specially focused on juvenile offenders, because of their lesser culpability. Thus, Roper held that the Eighth Amendment bars capital punishment for children, and Graham concluded that the Amendment also prohibits a sentence of life without the possibility of parole for a child who committed a nonhomicide offense. Graham further likened life without parole for juveniles to the death penalty itself, thereby evoking a second line of our precedents. In those cases, we have prohibited mandatory imposition of capital punishment, requiring that sentencing authorities consider the characteristics of a defendant and the details of his offense before sentencing him to death.  Here, the confluence of these two lines of precedent leads to the conclusion that mandatory life-without-parole sentences for juveniles violate the Eighth Amendment.

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