Montgomery v. Louisiana (January 2016)
Henry Montgomery received life without parole for a crime that happened when he was 17 years old. After Miller, Montgomery’s attorneys argued he should be resentenced, and the Supreme Court agreed. The Court reiterated Miller prohibits juveniles under the age of 18 from receiving mandatory life without the possibility of parole for homicide crimes. The Court left it up to the states to determine how to remedy sentences for juveniles convicted of homicide crimes and sentenced to mandatory life without parole.
Ultimately, the Court stated, the “opportunity for release will be afforded to those who demonstrate the truth of Miller’s central intuition–that children who commit even heinous crimes are capable of change.” Importantly, the Court also said: “Miller did bar life without parole … for all but the rarest of juvenile offenders, those whose crimes reflect permanent incorrigibility.”