People v. Holman (September 2017)
The Court held Miller applies to discretionary life without parole sentences for people under 18.
In some circumstances, life without the possibility of parole was mandatory for individuals convicted of murder when they were under the age of 18–that is what Miller originally addressed. In other circumstances, a life sentence is discretionary. Those cases may involve exceptionally “brutal or heinous” behavior or other factors. As a result of this holding, a person sentenced before they turn 18 may seek a new sentence if they show (1) they were subject to a life sentence, whether mandatory, discretionary, natural, or de facto, and (2) the sentencing court failed to consider youth and its attendant characteristics.
Holman’s trial and sentence were nevertheless found to be Miller compliant and upheld.