Court upholds life-without-parole sentence for Mississippi man convicted as juvenile

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Court upholds life-without-parole sentence for Mississippi man convicted as juvenile

Opinion analysis

By Amy Howe


at 1:04 p.m.

This article was updated on Thursday, April 22nd at 7:40 pm

The Supreme Court on Thursday declined to re-restrict states’ ability to sentence teenagers to life imprisonment without parole, and declined to challenge a Mississippi man, Brett Jones, who died of his grandfather’s stabbing death in 2004 Jones was 15 years old. Jones had argued that two recent Supreme Court rulings on mandatory decisions without parole for juveniles – the Miller v Alabama ruling in 2012 and the Montgomery v Louisiana ruling in 2016 – required the judge who sentenced him to find out that he was unable to rehabilitate himself before imposing a life without parole. With a 6-3 vote in Jones versus Mississippi, the judges disagreed and considered it sufficient for the judge to consider his youth in the conviction.

In a statement from Judge Brett Kavanaugh, the majority stated that the Supreme Court rulings in the Miller and Montgomery cases require that a judge or jury delivering a verdict make a separate determination that the defendant cannot be rehabilitated , “Rejected directly”. All Miller demanded, Kavanaugh wrote, was that “a convict consider youth as an extenuating factor in deciding whether to give life imprisonment without parole”.

Nothing in Montgomery, Kavanaugh went on, created additional requirements beyond those described in Miller. On the contrary, Kavanaugh stated that the court only seized Montgomery to determine whether the Supreme Court’s decision in the Miller case that the Eighth Amendment prohibits mandatory life sentences for juvenile offenders applies retrospectively to defendants, their convictions and Convictions had already passed to be final. A “key assumption” in both cases was that “the free judgment allows the convict to take into account the youth of the accused,” stated Kavanaugh, “thereby helping to ensure that life sentences without parole are only imposed in cases in which they are sentenced to whom this punishment is appropriate. ” Light of the defendant’s age. “If the Supreme Court had intended in these cases to impose the requirement prescribed by Jones, Kavanaugh suggested,” The Tribunal could easily have said this – and certainly would have said it. “But it did not, Kavanaugh noted, and in fact stated” exactly the opposite”.

Kavanaugh also dismissed Jones’ alternative argument – at least the convict should be asked to provide a statement in support of the sentence containing an “implicit statement” that the accused cannot be rehabilitated. Such a requirement, Jones said, would ensure “that the convict actually takes into account the youth of the accused.” The majority, however, remained unmoved and stated that “it would be next to impossible for a convicted person” to ignore the youth of the accused. And even the death sentences of the Supreme Court are not an analogous requirement for extenuating circumstances, stressed Kavanaugh.

In general terms, Kavanaugh stressed that the court’s decision “should not be construed as approval or disagreement with the judgment passed against Jones.” It is the job of states, not federal courts, to make the kind of “sweeping moral and political judgments” about what an appropriate sentence would be in a case like this. The Supreme Court’s role, Kavanaugh went on, is limited to determining whether the system used to convict Jones complied with the Eighth Amendment’s prohibition on cruel and unusual punishment – which it did, Kavanaugh reiterated, because life imprisonment is not there was compulsory and the trial judge had the discretion to impose a lesser sentence in light of Jones’ youth. “And in any case, according to Kavanaugh, the Supreme Court decision is” far from the final word whether Jones will be released from his sentence “: Jones claims, among other things, that he had a good record in prison and that it is different person than when he killed his grandfather. “

Judge Clarence Thomas agreed with the majority that the eighth amendment does not require a separate determination that a juvenile offender cannot be rehabilitated before he can be sentenced to life without parole. However, Thomas filed a separate statement criticizing the Montgomery court decision as a “demonstrably flawed” decision worthy of outright rejection. In Montgomery, Thomas said, the court should have recognized that its decision in the Miller case merely created a procedural rule that should not have been retroactive. Instead, wrote Thomas, Montgomery created “a categorical exception for certain offenders” that gave the court two options. The eighth amendment might turn out to actually impose the requirement proposed by Jones, or it might “just recognize that Montgomery has no legal or constitutional basis”. Instead, said Thomas, the majority opted for a third option: “Override Montgomery in terms of content, but not by name.”

Justice Sonia Sotomayor disagreed in an often sharply formulated opinion, which Judges Stephen Breyer and Elena Kagan followed. They accused the majority of “bias.”[ing] Miller and Montgomery beyond recognition. “Although Miller does not need any specific procedure to consider the accused’s youth or” require convicts to invoke magic words, “the convict must determine whether the accused is” one of those rare children whose crimes are irreparable corruption reflect, “she wrote.

In line with Thomas’ opinion, Sotomayor emphasized that the majority draw their conclusion through “twist”[ing] Precedent “: Miller is treated as a procedural rule rather than a substantive one. But she added:[a]No doubts that the Court might have as to the merits of these decisions do not justify setting aside those decisions. “According to the normal practice of the court, she stressed, it only deviates from its previous precedent if there is“ special justification ”for it – but the majority offered“ no such justification ”in this case. “How low,” she concluded, “has this court’s respect for rigid decisions sunk.”

Pushing back, Kavanaugh insisted Thursday’s decision “does not override Miller or Montgomery”. “Miller argued that a state cannot impose life imprisonment without parole on a murderer under the age of 18,” wrote Kavanaugh. “Today’s decision does not affect this company. Montgomery later held that Miller applies retrospectively “to defendants whose direct appeal had expired at the time the decision was published. “Today’s decision does not affect this participation either.” Instead, Kavanaugh concluded, the majority of him and his colleagues have “simply a bona fide disagreement with the dissent over the interpretation of these cases”.

Thursday’s decision was important in several ways. First and foremost, states can find it easier to get juvenile offenders to life without parole. Second, the 6-3 ruling shows how far the court has shifted to the right since its 5-4 ruling in Miller and its 6-3 ruling in Montgomery. Third, the opinions themselves show that tensions can be high even behind the scenes of the court, especially when it comes to meeting previous precedents.

This article was originally published by Howe on the Court.