Harrison, Mardi: Supreme Court of the United States Cases

Following transfer from state juvenile court to state circuit court and affirmation of transfer, defendant was convicted in the Alabama Circuit Court, Lawrence County, A. Phillip Reich II, J., of capital murder committed when he was 14 years old. Defendant appealed his conviction and the resulting sentence of life in prison without possibility of parole. The Alabama Court of Criminal Appeals, affirmed. In another case, after affirmance of a defendant's convictions in Arkansas for capital felony murder and aggravated robbery committed at age 14, defendant petitioned for state habeas relief, challenging his sentence of life in prison without possibility of parole. The Arkansas Circuit Court, Jefferson County, dismissed the petition. Defendant appealed. The Arkansas Supreme Court, affirmed. Certiorari was granted in each case.
Holding: The Supreme Court, Justice Kagan, held that mandatory life imprisonment without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment's prohibition on cruel and unusual punishments.

Excerpt from Westlaw

The State of Florida filed a probation violation report against defendant, who was on probation for crimes he had committed while a juvenile. The Circuit Court, Duval County, Lance M. Day, J., determined that a probation violation occurred and sentenced defendant to life imprisonment without the possibility of parole. Defendant appealed. The District Court of Appeal of Florida, First District, Wolf, J., affirmed and the Supreme Court of Florida, denied review. Certiorari was granted.
The Supreme Court, Justice Kennedy, held that:
(1) Eighth Amendment prohibits imposition of life without parole sentence on juvenile offender who did not commit homicide, and
(2) State must give juvenile nonhomicide offender sentenced to life without parole meaningful opportunity to obtain release.

Excerpt from Westlaw

Defendant convicted after he turned 18 of committing first-degree murder when he was 17, and sentenced to death petitioned for writ of habeas corpus. The Missouri Supreme Court, granted relief. Certiorari was granted.
The Supreme Court, Justice Kennedy, held that execution of individuals who were under 18 years of age at time of their capital crimes is prohibited by Eighth and Fourteenth Amendments.
Eighth

Excerpt from Westlaw