Sara Kruzman, a 35-year old inmate at the Central California Women’s Facility is a woman sentenced to death for killing her alleged pimp while she was a minor.[1] Following the announcement of the upcoming parole release of Sara, national attention has returned to the controversy surrounding juvenile sentencing as well as the legislation and court rulings regarding this issue.
Much of this controversy comes in the wake of the case, Miller v. Alabama, heard by the United States Supreme Court over a year ago. In the court opinion, released on June 25, 2012 by Justice Kagan, the Supreme Court ruled that juvenile mandatory life sentences without the possibility of parole violates the Eighth Amendment of the US Bill of Rights, which protects citizens from “cruel and unusual punishment.”[2] Using the rulings of previous juvenile justice court cases, most notably Roper v. Simmons and Graham v. Florida, the court explained that a mandated life sentence without the possibility of parole over looked the fundamental distinction between adults and minors. Teenagers, the court explained are likely to be highly influenced by their background and often cannot properly handle situations involving peer pressure. The court further asserts this judgment, writing, “[Mandatory life without parole for a juvenile] prevents taking into account the family and home environment… the circumstances of the homicide offense, including the extent of his participation…. and the possibility of rehabilitation.”[3] The court, however, specified that states were not required to promise release from prison;rather, they must make the opportunity present in the case of “maturity and rehabilitation.”[4]
Application of this ruling within individual states’ justice systems has been slower than expected, with many cautious about the social consequences of lighter sentencing, such as a higher crime rate.[5] This has resulted in numerous, non-uniform updates to state justice systems across the nation. For example, only in September 2013 did Massachusetts revise its general laws to include 17 year-olds in juvenile jurisdiction. Furthermore, the Massachusetts Chief Justice of the state juvenile court system explained that 17-year old defendants charged in the commonwealth in 2012 for any crime would have their charges transferred to juvenile court. However, at the time of the legislation’s passing, it was not officially ruled whether the sentences of all current inmates serving juvenile life without parole would be reviewed.[6] In Louisiana, we see the application of Miller v. Alabama to current and future juveniles facing trial, similar to the process explained in Massachusetts. However, in December of 2012, the Supreme Court of Louisiana, in the ruling, State v. Williams also applied the new sentencing regulations to the pre-sentenced inmates serving life without parole for crimes committed as a juvenile.[7]
In examining only these two states, both of which have legally applied the rulings of the United States Supreme Court, we already are able to see that there exist multiple interpretations of this case. While the Court’s ruling that juveniles, in the present and the future, may not be sentenced to life without parole, the Court made no clear distinction as to whether the ruling would also apply retroactively. Should an inmate currently serving life in prison for a crime committed as a juvenile be granted a sentence hearing or should that inmate be bound to the procedures used during the time their crime was committed? Furthermore, the Court cited a violation of the Eighth Amendment in sentencing minors to mandatory life without parole; therefore, one must question whether the individual rights of the inmates currently serving time under this punishment are infringed upon by a state’s decision not to review prior sentencing. These questions represent a true point of controversy with the functionality of the American Justice System, particularly in the juvenile system. The court’s vague rulings seem to be problematic, as there appears to be no clear and uniform response of states to the new decision. However, this vagueness allows the states to take into consideration their own situation and autonomy. It is this push-and-pull which we see defining the scene of the individual states’ juvenile justice system following the Supreme Court Ruling on Miller v. Alabama.
References:
[1] Associated Press, "California Governor Allows Freedom to Woman Who Killed Pimp." Last modified October 27, 2013. Accessed October 27, 2013. http://news.msn.com/crime-justice/calif-governor-allows-freedom-to-woman-who-killed-pimp.
[2] Miller v. Alabama, 132 S.Ct, 2455 (2012)
[3] Ibid.
[4] Ibid.
[5] The New York Times, "End Mandatory Life Sentences." Last modified September 16, 2013. Accessed October 27, 2013. http://www.nytimes.com/2013/09/17/opinion/end-mandatory-life-sentences.html?_r=0.
[6] Ring, Dan. The Republican Newspaper, "17-Year-Olds to be Treated as Juveniles in Massachusetts Courts Under Law Signed by Gov. Deval Patrick." Last modified September 18, 2013. Accessed October 29, 2013. http://www.masslive.com/politics/index.ssf/2013/09/gov_deval_patrick_signs_law_to.html.
[7] Equal Justice Initiative, "Louisiana Supreme Court Permits Retroactive Application of Miller v. Alabama." Last modified December 28, 2012. Accessed October 28, 2013. http://www.eji.org/node/728.