Miller v. Alabama

Overview of Miller v. Alabama:

Miller v. Alabama is a landmark supreme court case pertaining to the sentencing of juvenile criminal offenders. In this case, the supreme court decided it was unconstitutional to sentence a juvenile to life in prison without the possibility of parole. Subsequent juvenile offender criminal cases arose following Miller v. Alabama, further shaping the legal system. For example, in the Roper v. Simmons decision, the court ruled that the death penalty for crimes committed by juveniles was unconstitutional.

Miller v. Alabama case history:

In 2003, Evan Miller, a 14-year-old boy, had been drinking and using drugs with his juvenile friend in Moulton, Alabama. Miller and his friend got into an altercation with Miller’s neighbor after they tried robbing him. Miller and his friend subsequently attacked the neighbor and lit the neighbor’s trailer on fire. As a result of their actions, the neighbor died from head trauma and smoke inhalation. Miller was arrested and later convicted of capital murder. In 2006, Miller was sentenced to life in prison without the possibility of parole. While Miller was serving time in prison, Miller’s attorney appealed Miller’s conviction. Miller’s attorney argued the constitutionality of Miller’s conviction of life in prison without the possibility of parole. The attorney argued that Miller’s punishment was cruel and unusual for a child and violated the 8th Amendment of the Constitution. The 8th Amendment of the Constitution prohibits excessive fines, excessive bail, and cruel and unusual punishments. In 2012, a final decision from the Supreme Court ruled that mandatory life in prison without the possibility of parole sentences for juveniles under age 18 was unconstitutional. In the case of Montgomery v. Louisiana, the Supreme Court ruled that the Miller v. Alabama decision should be applied retroactively. These cases demonstrate the courts’ recognition that juvenile brains function differently from adults; therefore, juvenile sentencing should differ from adult sentencing. In addition, the courts recognized that a juvenile could benefit from prison vocational and self-help program thus increasing the likelihood of rehabilitation.

Mitigating factors in Miller’s life:

It is important to note several mitigating family and environmental factors in Miller’s background. Miller was raised in a dysfunctional household filled with violence, neglect, addiction, and poverty. Miller’s mother suffered from substance abuse addiction, and his father was abusive. He was exposed to a childhood of instability due to his family constantly changing homes. Eventually, Miller was removed from his parent’s custody and entered the foster care system; his parents later divorced. During his childhood, Miller developed a substance abuse problem and struggled with his mental health.

Application of Miller v. Alabama to forensic psychology:

In Miller V. Alabama, neuroscience research and developmental psychology impacted the court’s decision. Forensic psychologists often conduct evaluations on juveniles who have committed homicide. One necessary juvenile-related forensic evaluation concept is diminished culpability. It is often used in Franklin Hearing Type of Evaluations or resentencing type of evaluations in California. Diminished culpability occurs when an individual does not fully understand their wrongdoings. As a result of diminished culpability, the juvenile should not receive life in prison without the possibility of parole for the act(s) of wrongdoing. In the case of Miller v. Alabama, three aspects of diminished culpability were taken into consideration which are:

• immaturity (children lack maturity in decision-making),
• vulnerability (children are more likely to be influenced), and
• changeability (children are not fully developed and have the potential to change).

Developmentally, juveniles vary from adults; therefore, mitigating factors should be considered when juveniles are exposed to the criminal justice system. In the Miller v. Alabama case, the court considered five factors when deciding if the juvenile should be sentenced to life without the possibility of parole. These factors included:

• maturity and age at the time of the offense,
• environmental influences,
• circumstances of the crime committed,
• disadvantages the juvenile faced with the justice system, and the
• juvenile’s changeability.

The factors mentioned above later came to be known as the Miller factors. The Miller factors are essential when considering whether a juvenile offender can be rehabilitated. The expertise of forensic clinicians (psychologists and psychiatrists) is vital for the legal system because forensic clinicians evaluate brain development and behavioral functioning in juveniles. Forensic clinicians use their developmental and behavioral science knowledge to educate legal parties and the court.

When to seek emergency help?

Immediately call 911 or your local emergency number if you or someone you know is thinking about self-harm, suicide, or homicide or is in psychiatric distress. If you are with someone thinking about hurting themselves, stay with the person to keep them safe until emergency services arrive at your location.

• 988 Suicide & Crisis Lifeline (Call or Text 988)
• Veterans Crisis Line (1-800-273-8255, Press 1 to talk)
• Text Hello to 741741

Use the following telephone number for non-emergency services in LA County (the entry point for mental health services with the Los Angeles County Department of Mental Health).

• LACDMH ACCESS LINE: 800-854-7771

If you are interested in a psychological evaluation by one of our psychologists at Vienna Psychological Group, book your free 30-minute consultation here.

To learn more about mental health and forensic psychology, check out our blog library here and our podcast, The Forensic Psychologist Podcast, hosted by Dr. Vienna on Spotify and Apple Podcasts.

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This blog aims to answer general questions and assist readers in better understanding Miller V. Alabama. This blog is not intended to provide medical, psychiatric, or legal advice.

References:

John F. Stinneford, Youth Matters: Miller v. Alabama and the Future of Juvenile Sentencing, 11 Ohio St. J. Crim. L. 1 (2013), available at http://scholarship.law.ufl.edu/facultypub/423.

Piel, J. (2020). Term-of-years sentences since Miller v. Alabama. Journal of the American Academy of Psychiatry and the Law Online, 48(1), 98-104.