Supreme Court Issues Important Opinion for Californians Sentenced to Life Without the Possibility of Parole for a Juvenile Offense

Recently, the United States Supreme Court issued an opinion in the case of Jones v. Mississippi. The case required the Court to determine the proper procedure that a court must follow when sentencing a juvenile offender to life in prison without the possibility of parole.

Historically, juveniles were frequently charged as adults. It wasn’t until relatively recently that the juvenile justice system came into existence. The juvenile justice system has a primary focus on rehabilitation. Minors can also “age out” of the juvenile justice system, limiting the length of time they are subject to incarceration or supervision. Thus, whenever possible, juveniles benefit from staying in the juvenile justice system.

For the most part, juveniles who are charged as adults face the same punishments that adults do. There are two important exceptions: the death penalty and life in prison without the possibility of parole (JLWOP). In recent years, the U.S. Supreme Court has held that juveniles cannot be sentenced to death. Subsequently, the Court determined that, while juveniles can be sentenced to life in prison without the possibility of parole, a trial court must follow strict procedures that allow proper consideration of the defendant’s age.

In the Court’s most recent opinion involving JLWOP, the Court was tasked with determining whether Mississippi’s JLWOP statute was constitutionally sufficient given recent legal developments.

In that case, the defendant was charged with the murder of his grandfather. At the time of the offense, the defendant was 15 years old. A jury convicted the defendant, and a judge sentenced him to LWOP. After the Court’s decision in Miller v. Alabama, the Mississippi Supreme Court ordered the defendant was eligible for a resentencing.

At the defendant’s resentencing, the judge again sentenced him to LWOP, finding that it remained the appropriate sentence. The defendant filed a post-conviction petition, claiming that the resentencing judge failed to consider whether he was “permanently incorrigible.” The defendant maintained that this was a necessary finding to resentence a juvenile to LWOP.

The Supreme Court rejected the defendant’s argument. The Court explained that the resentencing court need only consider “an offender’s youth and attendant characteristics” before resentencing. The Court held that there was no requirement that a court finds the defendant to be permanently incorrigible and that as long as a state’s sentencing structure provided for the consideration of the defendant’s youth and the impact it had on the commission of the offense, it was constitutionally sound.