Case law · Highest court · Federal

Montgomery v. Louisiana

Decided
January 25, 2016
Docket
14-280
Status
Published
Jurisdiction
Federal

Cited 2,780 timesNo negative treatment found in this library

What later courts said

  • holding that Miller applies retroactively to cases in which state courts collaterally review sentences imposed prior to Miller — Vasquez v. Commonwealth (2016)
  • holding that a State may remedy a Miller violation, without re-litigating the sentence, by affording the offender an opportunity for eventual release on parole — Martinez v. State (2019)
  • holding that Miller’s procedural requirements to consider characteristics of youth when sentencing juvenile offenders provides a substantive rule that applies retroactively — D. Steilman v. Michael (2017)

Each line is a later court’s own words about this case, not a summary. Read the opinion before relying on it.

How the opinion begins

Justice KENNEDY delivered the opinion of the Court.

This is another case in a series of decisions involving the sentencing of offenders who were juveniles when their crimes were committed. In Miller v. Alabama, 567 U.S. ----, 132 S.Ct. 2455, 183 L.Ed.2d 407 (2012), the Court held that a juvenile convicted of a homicide offense could not be sentenced to life in prison without parole absent consideration of the juvenile's special circumstances in light of the principles and purposes of juvenile sentencing. In the wake of Miller , the question has arisen whether its holding is retroactive to juvenile offenders whose convictions and sentences were final when Miller was decided. Courts have reached different conclusions on this point. Compare, e.g., Martin v. Symmes, 782 F.3d 939, 943 (C.A.8 2015) ; Johnson v. Ponton, 780 F.3d 219, 224-226 (C.A.4 2015) ; Chambers v. State, 831 N.W.2d 311, 331 (Minn.2013) ; and State v. Tate, 2012-2763, p. 17 (La.11/5/13), 130 So.3d 829, 841, with Diatchenko v. District Attorney for Suffolk Dist., 466 Mass. 655, 661-667, 1 N.E.3d 270, 278-282 (2013) ; Aiken v. Byars, 410 S.C. 534, 548, 765 S.E.2d 572, 578 (2014) ; State v. Mares, 2014 WY 126, ¶¶ 47-63, 335 P.3d 487, 504-508 ; and People v. Davis, 2014 IL 115595, ¶ 41, 379 Ill.Dec. 381, 6 N.E.3d 709, 722. Certiorari was granted in this case to resolve the question.

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Statutes cited

Cite this

Montgomery v. Louisiana, 577 U.S. 190 (2016)

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