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How Does Miller v Alabama Impact Juvenile Sentencing?

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Back in 2017, the Supreme Court heard a case called Miller v Alabama. The case questioned whether a juvenile can fairly be sentenced to life in prison without the possibility of parole. The case was filed by attorneys for a young man named Evan Miller.

When Miller was just 14 years old, he beat his neighbor to death and set his trailer on fire. When he wrapped the man’s body in a sheet, he yelled that he was God and had the right to kill the man. Miller was sentenced to life in prison without the possibility of parole.

In 2017, Miller’s attorneys filed a motion with the Supreme Court, arguing that this sentence was unconstitutionally harsh. The court heard the case and decided in favor of the defendant. They found that life without the possibility of parole is an unfair sentence for offenders under the age of 18.

California was one of the first states to basically outlaw the sentence of life in prison for young offenders. In 2012, California passed Senate Bill 9, which basically prohibits a life sentence for juvenile offenders under the age of 18. Once the bill was passed, teenage defendants in California could file motions to have a resentencing hearing be held in their case. This gave people previously sentenced to life in prison the chance of having their sentence commuted or reduced.

Clearly, California saw the trend before the rest of the county. The question is, how will things change now that the Miller v Alabama decision has been handed down and Senate Bill 9 has passed?

How are Cases Decided Under Senate Bill 9 (SB9)?

The first case filed under SB 9 was that of Edel Gonzalez. Gonzalez was convicted in 1991 of an attempted carjacking. Despite the fact that Gonzalez had no weapon and no criminal record, the court found him guilty. He was sentenced to life in prison without the possibility of parole.

Once SB9 was passed, a law firm in California took on Gonzalez’s case pro bono. Four lawyers headed up his team in an effort to get a resentencing hearing under the bill. The court accepted his petition and review his case.

The court found that Gonzalez was certainly eligible for resentencing under Senate Bill 9. The factors the court took into account included:

  • Gonzalez was a juvenile at the time of the offense
  • He had no criminal record at the time
  • There was no weapon, and he did not injure anyone during the commission of the crime
  • He had an exemplary behavioral record in jail with no alcohol or drug issues
  • He had the lowest risk score of “1” when the jail completed a risk assessment
  • Gonzalez spoke on his own behalf explaining why he deserved a second chance

Gonzalez was 38 at the time of his motion and spent half his life in prison. His request was granted and the court resentenced him to 25 years to life. Since he had already served 22 years, he would be eligible for parole in just three (3) years.

Cases Decided Under Miller v Alabama Have Had Mixed Results

In Miller v Alabama, the court held that some defendants convicted of crimes as teenagers would be eligible for re-sentencing hearings. This doesn’t mean that all prisoners sentenced as teenagers will receive reduced sentences.

The court in Miller v Alabama recognized that kids under 18 have diminished capacity and can’t fully appreciate the nature of their actions. So, someone at 14 simply doesn’t understand the difference between right and wrong. Their brains haven’t fully developed at this young age.

One of the questions the court will ask in these cases is whether the offender was “irreparably corrupt.” This term may seem vague, and it is. This is intentional. The court wanted to leave open the option of confirming life sentences for youth offenders. They believe that there are some people are who incapable of living in society. They are simply too great a risk to let them out of jail.

The court will look at several factors to determine if someone is irreparably corrupt. These factors include:

  • The age at the time the crime was committed
  • The nature of the crime itself
  • The defendant’s remorse, both at trial and now
  • The defendant’s prison record
  • Any psychological evaluations of the defendant

So far, over 10 states have filed cases under Miller v Alabama. The results have been mixed. To date, the decisions have really been decided on a case by case basis. Most of the cases are still pending.

If your child has been charged with a serious crime in San Diego, you should call and speak with an experienced San Diego criminal lawyer today.

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