Over the period from 2010 to 2016 the U.S. Supreme Court delivered its rulings in a range of landmark criminal cases, dealing with diverse topics, such as freedom from unreasonable searches and seizures, rights regarding counsel, detainment of suspects in terrorism, as well as criminal sentences. The case Miller v Alabama (2012) belongs to the last category. The major finding of the Court in this case was that mandatory sentences of life, not including the parole possibility, are unconstitutional in relation to juvenile offenders.
The case was referred to the Supreme Court by Evan Miller, a 14-year boy, who was sentenced to life. Acting together with his friend of similar age, Evan Miller committed a homicide by setting fire in a trailer, where his friend and he tended to buy drugs from a neighbor.
The case is appealing to me in several domains. Firstly, I am interested in juvenile justice, and keep an eye on all the Supreme Court cases that relate to this field. Secondly, the case has an interesting line of reasoning that includes reconsidering several previous cases, where juvenile criminals were tried as adults (charged with a life term without the right to parole). Thus, current case is of special interest due to the fact that it led to overcoming an existing approach to charging juvenile criminals.
At the same time, the case followed the general line of Ropper v Simmons (2005) and Graham v Florida (2010) that acknowledged the constitutionality of diminished culpability of children in criminal cases, not relating to life sentence. Furthermore, the sentence will affect a variety of rulings, because laws of twenty states in the U.S. tended to provide for life sentence without a parole for juveniles, who committed homicide. Lower courts are currently obliged to reconsider existing sentences.
Considering the case, the judges took into account different sources of criminal law. Thus, the legislation of Alabama and a range of the U.S. Supreme Court cases were considered. The cases under study included inter alia Jackson v State (2003), Ropper v Simmons (2005) and Graham v Florida (2010).
The above cases mostly dealt with constitutionality of specific legislative norms under Eighth Amendment, protecting an individual from cruel and unusual punishment. For example, in Ropper v Simmons (2005) the U.S. Supreme Court found that it is unconstitutional to impose capital punishments for crimes that are committed by individuals, who did not reach the age of eighteen. Prior to the landmark decision in Ropper v Simmons (2005) there has been twenty nine juvenile offenders, who were executed since 1976. In Miller v Alabama (2012) the Supreme Court dealt with two jurisdictions: federal and the one of Alabama state. Criminal law, related to in the case, is tightly interconnected with the Eighth Amendment and the concept of national consensus.
The notion of criminal liability refers to the liability that arises from one’s committing a criminal act or breaking a law. In turn, accomplice liability allows a court to sentence a person for a crime, committed by another person. If an individual encourages, aids or assists one in the commission of the crime, he/she is considered to be accomplice to the crime. At the same time, a person, who actually committed a crime, is referred to as a principal. In the case under study, only the notion of criminal liability is applicable. Evan Miller and his friend acted together, when committing a crime, and, thus, both of them are criminally liable for homicide.
The elements of a crime are as follows. They include means rea (mental state of a defendant), conduct (actus rea), concurrence of means rea and actus rea, as well as causation.
Actus reus is a critical element of the crime that characterizes its physical aspect. Actus reus can be reflected in the form of an act or an omission (failure to act). The crucial thing about the act as a form of actus reus is that the act is to be committed voluntarily. The Model Penal Code provides the list of acts that are considered not to be voluntarily. They can include, for instance, a reflex or convulsion, as well as a bodily movement that takes place during unconsciousness or sleep. Omission (failure to act) is usually not considered to constitute an act and cause liability. However, the statutes tend to single out particular situations, when omission leads to liability.
“Means rea” is Latin for “guilty mind”. This element of the crime characterizes its mental aspect, accompanying the actus reus. The levels (modes) of means rea are different across the U.S. jurisdictions. Determining the mode of culpability is crucial for deciding the cases. Basic modes of culpability include a purposeful act, a knowing act, a reckless and a negligent act. While in the case of purposeful act one aims to cause a specific result, when acting, the concept of knowing act provides for knowing that the result can take place, but not willing it to occur. A reckless act takes place, when an individual consciously disregards the risk, associated with his actions. This risk is to be substantial and justifiable. Finally, negligent act is not concerned with conscious disregard of the risk.
Concurrence is a crucial element of the structure of a crime. While not every act needs to be characterized with means rea, actus reus is essential When both elements are required, they have to concur. The concurrence means that mental aspect of the crime serves as a foundation for committing an act.
In current case, actus reus was manifested by setting a fire in a trailer. The accused set a fire purposefully to avoid paying for drugs. Means rea and actus reus concurred.
Denno, D, McGivney, A.A. (2009). Selected Model Penal Code provisions. Retrieved 26 January 2016 from http://wps.prenhall.com/wps/media/objects/13023/13335893/downloadables/model_penal_code_sel_sec2.pdf
Miller v Alabama, 567 U.S. ____(2012)
Roper v. Simmons, 543 U.S. 551 (2005)