Supreme Court of the United States
Henry Montgomery, Petitioner v. Louisiana.
January 25, 2016136 S. Ct. 718
Summary
The Supreme Court held that Miller v. Alabama announced a new substantive rule of constitutional law — barring life without parole for all but the rarest juvenile offenders whose crimes reflect irreparable corruption — and that the Constitution requires state collateral review courts to give retroactive effect to new substantive rules, so Henry Montgomery, automatically sentenced to life without parole in 1970 for a 1963 murder committed at age 17, must be given an opportunity to show his crime did not reflect irreparable corruption. The Court also confirmed its jurisdiction, reasoning that a state court's refusal to give retroactive effect to a controlling substantive constitutional rule implicates a federal right, and noted that a State may remedy a Miller violation by making juvenile homicide offenders eligible for parole rather than resentencing them. The Louisiana Supreme Court's judgment was reversed and remanded. Justice Scalia, joined by Justices Thomas and Alito, dissented on both jurisdiction and the merits, arguing the Court rewrote Miller as a categorical bar; Justice Thomas wrote separately to contend that the jurisdictional holding lacks any foundation in the Constitution's text or historical traditions.
Holding
- Whether the Court has jurisdiction to review the Louisiana Supreme Court's refusal to give Miller retroactive effect on state collateral review.. Yes. When a new substantive rule of constitutional law controls the outcome of a case, the Constitution requires state collateral review courts to give retroactive effect to that rule; a state court's refusal implicates a federal right and is reviewable. The holding is limited to Teague's first exception for substantive rules; the constitutional status of the watershed-rules exception need not be addressed.
- Whether Miller announced a new substantive rule of constitutional law.. Yes. Miller barred life without parole for all but the rarest juvenile offenders, those whose crimes reflect permanent incorrigibility, rendering it an unconstitutional penalty for a class of defendants because of their status — juvenile offenders whose crimes reflect transient immaturity. Its individualized-sentencing requirement is a procedural component that implements, and does not transform, this substantive guarantee.
- Whether Miller's substantive rule applies retroactively on collateral review and what remedy suffices.. Yes. Because Miller announced a substantive rule, it is retroactive in cases on collateral review; prisoners like Montgomery must be given the opportunity to show their crimes did not reflect irreparable corruption and, if not, their hope for some years of life outside prison must be restored.
Docket 14-280
Cited authorities
- 38 U. Chi. L. Rev. 142
- Wyo. Stat. Ann. § 6-10-301
- 110 Stat. 1219
- 28 U.S.C. § 2254