Montgomery v. Louisiana Opinion
On January 25th, 2016, the United States Supreme Court ruled 6-3 that its 2012 decision in Miller v. Alabama applied retroactively to the more than 2600 individuals previously sentenced to life without parole as children.
Henry Montgomery, the petitioner in the case, was sentenced to life without parole for a crime committed when he was 17 years old in 1963, almost 50 years before the decision in Miller. Louisiana courts declined to apply Miller retroactively to cases like Mr. Montgomery’s.
Justice Kennedy, writing for the majority, overturned the state court’s decision and found that, under a prior Supreme Court decision, Teague v. Lane, 489 U.S. 288 (1989), Miller announced a new substantive rule that applies retroactively. Justice Kennedy explained: “because Miller determined that sentencing a child to life without parole is excessive for all but ‘the rare juvenile offender whose crime reflects irreparable corruption,’ it rendered life without parole an unconstitutional penalty for ‘a class of defendants because of their status’—that is, juvenile offenders whose crimes reflect the transient immaturity of youth. As a result, Miller announced a substantive rule of constitutional law.” 136 S.Ct. 718, 724 (2016) Therefore, “Miller is retroactive because it ‘necessarily carr[ies] a significant risk that a defendant’—here, the vast majority of juvenile offenders— ‘faces a punishment that the law cannot impose upon him.’” Id.
Cert Petition and Opposition Filed in Montgomery v. Louisiana
Party Briefs Filed in Montgomery v. Louisiana
Montgomery v. Louisiana Oral Argument