The ruling left open the possibility of judges' sentencing juveniles to life imprisonment without parole in individual circumstances but said state laws could not automatically impose such sentences.
“Mandatory life without parole for a juvenile precludes consideration of
his chronological age and its hallmark features — among them,
immaturity, impetuosity, and failure to appreciate risks and
consequences,” Justice Elena Kagan wrote for the majority. “It prevents
taking into account the family and home environment that surrounds him —
and from which he cannot usually extricate himself — no matter how
brutal or dysfunctional.”
Justice Kagan’s opinion argued that the cases, involving 14-year-old boys who had taken part in murders in Arkansas and Alabama, were an extension of the court’s recent rulings on the young, which asserted that they still had unformed emotional and moral structures and that treating them as adults violated “the evolving standards of decency that mark the progress of a maturing society.”
From Scotusblog:
. . . . there presently are approximately seventy-nine individuals currently serving life-without-parole sentences for crimes they committed at age thirteen or fourteen. The Court further explains that approximately 2500 people are serving life without parole for crimes they committed before they were eighteen.
The Court’s opinion brings together two strands of precedent to hold that a mandatory life-without-parole sentence for juveniles violates the Eighth Amendment. The first strand holds that the Eighth Amendment categorically prohibits punishments that enact a mismatch between the culpability of a class of offenders and the severity of the penalty. Citing, among cases, Roper and Graham, the Court explains that juveniles have always been regarded as less culpable because the distinctive attributes of youth diminish the penological justifications for imposing the harshest penalties on juvenile offenders, even when they commit severe crimes. The second line of precedent holds that life without parole shares key characteristics with the death penalty, and thus raises similar Eighth Amendment concerns, most notably that defendants are entitled to individualized consideration when facing such a severe sanction.
