''Jones v. Mississippi'', 593 U.S. ___ (2021), was a
United States Supreme Court
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point ...
case regarding the imposition of
life sentence
Life imprisonment is any sentence of imprisonment for a crime under which convicted people are to remain in prison for the rest of their natural lives or indefinitely until pardoned, paroled, or otherwise commuted to a fixed term. Crimes for ...
s
for juveniles. The Supreme Court had previously ruled in ''
Miller v. Alabama
''Miller v. Alabama'', 567 U.S. 460 (2012), was a United States Supreme Court case in which the Court held that ''mandatory'' sentences of life without the possibility of parole are unconstitutional for juvenile offenders. The ruling applied even ...
'' in 2012 that mandatory life sentences without parole for juvenile offenders was considered
cruel and unusual punishment
Cruel and unusual punishment is a phrase in common law describing punishment that is considered unacceptable due to the suffering, pain, or humiliation it inflicts on the person subjected to the sanction. The precise definition varies by jurisd ...
outside of extreme cases of permanent
incorrigibility, and made this decision retroactive in ''
Montgomery v. Louisiana'' in 2016. In ''Jones'', a juvenile offender who was 15 at the time of his offense, challenged his life sentence following ''Montgomery'' but was denied by the state. In a 6–3 decision with all six conservative justices upholding the life sentence without parole for Jones, the Court ruled that the states have discretionary ability to hold juvenile offenders to life sentences without parole without having to make a separate assessment of their incorrigibility.
Background
On August 9, 2004, 15-year-old Mississippi resident Brett Jones (born July 17, 1989) fatally stabbed his grandfather Bertis after a confrontation over Brett's girlfriend. Jones claimed in court his action was in self-defense. In 2005, he was convicted in
Lee County Circuit Court and sentenced to life in prison without the possibility of parole, the mandatory sentence under state law.
In 2012, the Supreme Court ruled in ''
Miller v. Alabama
''Miller v. Alabama'', 567 U.S. 460 (2012), was a United States Supreme Court case in which the Court held that ''mandatory'' sentences of life without the possibility of parole are unconstitutional for juvenile offenders. The ruling applied even ...
'' that mandatory life sentences without the possibility of parole for juveniles was considered a cruel and unusual punishment under the
Eighth Amendment to the United States Constitution
The Eighth Amendment (Amendment VIII) to the United States Constitution protects against imposing excessive bail, excessive fines, or cruel and unusual punishments. This amendment was adopted on December 15, 1791, along with the rest of th ...
, and that judges in such cases should be able to consider other factors that may influence such acts. The ruling of ''Miller v. Alabama'' was made retroactive to all previous cases in the Supreme Court's decision ''
Montgomery v. Louisiana''. The decision of ''Montgomery'' barred the use of life sentences without parole "for all but the rarest of juvenile offenders, those whose crimes reflect permanent incorrigibility".
Following ''Miller'' and ''Montgomery'', several states adjusted their laws to reflect the Court's rulings but Mississippi remained a state where life sentences could still be handed to juveniles determined to be incorrigible.
The state of Mississippi granted Jones a rehearing as a result of ''Montgomery'', but still resentenced him to a life sentence without parole. According to Jones' lawyer, the state court failed to consider any aspect related to the "permanent incorrigibility" or potential for rehabilitation, thus violating the ruling from ''Montgomery'', and thus sought appeals through the Supreme Court.
Supreme Court
Prior to certifying Jones' case, the Supreme Court had been considering the case of ''Mathena v. Malvo'' (Docket 18-217), a similar case from Virginia involving
Lee Boyd Malvo that raised the question if courts must determine if a juvenile is deemed incorrigible before passing a life sentence. Oral arguments had been held in October 2019, during which the Justices referred back to ''Montgomery''; Justice Kavanaugh recognized that a ruling had to differentiate "someone who's merely immature as opposed to incorrigible". Due to a change in Virginia's state law, the case was rendered
moot before the Court could deliver the opinion.
Jones' case was granted by the Supreme Court in March 2020.
Oral arguments were held on November 3, 2020.
The Court issued its decision on April 22, 2021. The Court affirmed the Mississippi Court of Appeals decision to maintain Jones' life sentence in a 6–3 vote.
Justice
Brett Kavanaugh
Brett Michael Kavanaugh ( ; born February 12, 1965) is an American lawyer and jurist serving as an associate justice of the Supreme Court of the United States. He was nominated by President Donald Trump on July 9, 2018, and has served since ...
wrote the majority opinion, which was joined by Chief Justice
John Roberts
John Glover Roberts Jr. (born January 27, 1955) is an American lawyer and jurist who has served as the 17th chief justice of the United States since 2005. Roberts has authored the majority opinion in several landmark cases, including '' Nat ...
and Justices
Samuel Alito,
Neil Gorsuch
Neil McGill Gorsuch ( ; born August 29, 1967) is an American lawyer and judge who serves as an associate justice of the Supreme Court of the United States. He was nominated by President Donald Trump on January 31, 2017, and has served sinc ...
, and
Amy Coney Barrett
Amy Vivian Coney Barrett (born January 28, 1972) is an associate justice of the Supreme Court of the United States. The fifth woman to serve on the court, she was nominated by President Donald Trump and has served since October 27, 2020. ...
. Justice Kavanaugh wrote in his opinion that "Determining the proper sentence in such a case raises profound questions of morality and social policy. The States, not the federal courts, make those broad moral and policy judgments in the first instance when enacting their sentencing laws. And state sentencing judges and juries then determine the proper sentence in individual cases in light of the facts and circumstances of the offense, and the background of the offender." As such, Kavanaugh concluded that "a discretionary sentencing system is both constitutionally necessary and constitutionally sufficient".
Justice
Clarence Thomas
Clarence Thomas (born June 23, 1948) is an American jurist who serves as an associate justice of the Supreme Court of the United States. He was nominated by President George H. W. Bush to succeed Thurgood Marshall and has served since 19 ...
concurred in the judgment.
Justice
Sonia Sotomayor
Sonia Maria Sotomayor (, ; born June 25, 1954) is an American lawyer and jurist who serves as an associate justice of the Supreme Court of the United States. She was nominated by President Barack Obama on May 26, 2009, and has served sinc ...
wrote the dissenting opinion joined by Justices
Stephen Breyer
Stephen Gerald Breyer ( ; born August 15, 1938) is a retired American lawyer and jurist who served as an associate justice of the U.S. Supreme Court from 1994 until his retirement in 2022. He was nominated by President Bill Clinton, and re ...
and
Elena Kagan
Elena Kagan ( ; born April 28, 1960) is an American lawyer who serves as an associate justice of the Supreme Court of the United States. She was nominated by President Barack Obama on May 10, 2010, and has served since August 7, 2010. Kagan ...
. Sotomayor wrote that the majority opinion was "an abrupt break from precedent".
She continued that "The question is whether the state, at some point, must consider whether a juvenile offender has demonstrated maturity and rehabilitation sufficient to merit a chance at life beyond the prison in which he has grown up. For most, the answer is yes."
See also
* ''
Graham v. Florida'' (2010)
* ''
Roper v. Simmons
''Roper v. Simmons'', 543 U.S. 551 (2005), was a landmark decision in which the Supreme Court of the United States held that it is unconstitutional to impose capital punishment for crimes committed while under the age of 18. The 5–4 decision ov ...
'' (2005)
References
External links
*
{{US8thAmendment, punishment
United States Supreme Court cases of the Roberts Court
United States Eighth Amendment case law
Juvenile justice system
Life imprisonment
2021 in United States case law
United States Supreme Court cases