One night in 2003, Evan Miller, who was 14 years old, was smoking marijuana with another juvenile and an adult, Cole Cannon, at Cannon’s trailer. When Cannon passed out, Miller stole his wallet, splitting about $ 300 with the other juvenile. When Miller tried to put the wallet back into Cannon’s pocket, Cannon awoke and grabbed Miller. Miller grabbed a baseball bat and repeatedly struck Cannon with it. Miller placed a sheet over Cannon’s head, told him “I am God, I’ve come to take your life,” and delivered one more blow. Cannon was not dead. Miller and his accomplice set Cannon’s trailer on fire. Cannon died from his injuries and smoke inhalation. Miller was caught and was tried as an adult as permitted by Alabama law. Miller was convicted of murder in the course of arson. Under Alabama law, the crime carried a mandatory minimum punishment of life in prison without the possibility of parole, which was assessed against Miller. Miller challenged the sentence, alleging that a minimum sentence of life in prison without the possibility of parole assessed against a juvenile constitutes cruel and unusual punishment in violation of the Fifth Amendment to the U. S. Constitution.
Does Alabama’s mandatory sentencing requirement of life imprisonment without the possibility of parole as applied to juvenile defendants constitute cruel and unusual punishment in violation of the Fifth Amendment? Miller v. Alabama, 132 S. Ct. 2455, 2012 U. S. Lexis 4873 (Supreme Court of the United States, 2012)