After holding in 2010, in Graham v. Florida, that juveniles may not be sentenced to life without parole for non-homicide crimes, the U.S. Supreme Court will again review the constitutionality of death in prison sentences for juvenile offenders.
In Jackson v. Hobbs, the Arkansas Supreme Court upheld a life without parole sentence for a 14-year-old convicted of an unintentional killing where he was not the triggerman. In Miller v. Alabama, an Alabama appeals court upheld a sentence of life imprisonment without parole imposed on a 14-year-old convicted of intentional murder. Both sentences were mandatory and did not permit any consideration of the juvenile’s age or adolescent status. The Supreme Court will hear oral arguments on both cases on March 20, 2012, and is expected to issue a decision in the spring.
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