On a hot summer night in 2003, 14-year-old Evan Miller and 16-year-old Colby Smith found Cole Cannon, a neighbor, passed out in his Lawrence County, Alabama trailer. The two teens went into Cannon’s trailer to steal some money. Cannon awoke while Miller was pulling $300 out of Cannon’s pocket. A fight ensued between Cannon and Miller, with Miller beating Cannon with his hands and a baseball bat. Miller returned to Cannon’s trailer and set it on fire to conceal evidence of the crime. The fire killed Cannon.
The prosecution charged Miller with homicide. Miller was tried as an adult, due to the gruesomeness and viciousness of the murder. The trial court convicted Miller of first degree homicide and sentenced him to life in prison without parole. After a series of appeals, the case went to the United States Supreme Court.
Supreme Court Hears the Case
The Eighth Amendment to the United States Constitution provides: “Excessive bail shall not be required, nor excessive fines imposed, nor cruel and unusual punishments inflicted.”
The Miller case presented the Supreme Court with the question as to whether sentencing a minor to life without parole violated the Eighth Amendment’s cruel and unusual punishment clause. The Supreme Court found that Miller’s sentence, in its then form, constituted cruel and unusual punishment. Justice Elena Kagan, writing for the majority, stated that sentencing a minor to life in prison without parole may be unconstitutional because mitigating factors must be considered. Those factors include immaturity and the failure to fully appreciate the consequences of his actions.
Note that this ruling did not strike down all life without parole sentences to juveniles; instead, the ruling requires courts to consider the above-mentioned and other juvenile factors before sentencing a minor to life in prison without parole.
As a result of the ruling, the case was remanded to the Alabama trial court to reconsider Miller’s sentencing consistent with the Supreme Court’s ruling.
Aftermath of the Ruling
In the aftermath of the Miller case, nine states abolished life in prison without parole for juvenile offenders while two other states severely limited the penalty for juveniles. At the time of the ruling, there were an estimated 2,500 juveniles serving sentences of life in prison without parole. That number has since dropped.
For Evan Miller, he awaits a hearing for resentencing because the Alabama legislature has yet to adopt standard guidelines for juvenile offenders. Votes on the bill failed twice.
The Supreme Court’s ruling is also applied retroactively. In 2016, the Supreme Court considered the case of Montgomery v. Louisiana, wherein Montgomery committed the crime of murder when he was 17, even though it is 50+ years later. Montgomery appealed the ruling of the court based on the Supreme Court’s understanding of the Miller case and the Eighth Amendment cruel and unusual punishment clause. The Supreme Court agreed with Montgomery that the trial court should consider juvenile tendencies retroactively.
If you are facing criminal charges in Alabama, contact a law firm with the expertise and skill to provide you with an effective representation. Contact the law firm of Parkman White.