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Jones v. Mississippi

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Supreme Court of the United States
Jones v. Mississippi
Term: 2020
Important Dates
Argument: November 3, 2020
Decided: April 22, 2021
Outcome
Affirmed
Vote
6-3
Majority
Brett Kavanaugh • Chief Justice John G. Roberts • Samuel Alito • Neil Gorsuch • Amy Coney Barrett
Concurring
Clarence Thomas
Dissenting
Sonia Sotomayor • Stephen Breyer • Elena Kagan


Jones v. Mississippi is a case argued before the Supreme Court of the United States on November 3, 2020, during the court's October 2020-2021 term.

The court affirmed the decision of the Mississippi Court of Appeals in a 6-3 ruling, holding that the U.S. Supreme Court's rulings in Miller v. Alabama and Montgomery v. Louisiana do not require a sentencing judge to make a separate finding that a juvenile convicted of murder is permanently incorrigible before imposing a sentence of life without parole. A discretionary sentencing system where the sentencer can take the defendant's age into account is constitutionally sufficient.[1] Justice Brett Kavanaugh delivered the majority opinion of the court and Justice Clarence Thomas wrote an opinion concurring in the judgment. Justice Sonia Sotomayor wrote a dissenting opinion joined by Justices Stephen Breyer and Elena Kagan.

HIGHLIGHTS
  • The case: When he was 15 years old, Brett Jones killed his grandfather. Jones was tried for murder in the Circuit Court of Lee County, Mississippi. He was convicted and sentenced to life imprisonment without parole. Following the U.S. Supreme Court's decision in Miller v. Alabama (2012), the Mississippi Supreme Court ordered the county circuit court to hold a sentencing rehearing. The circuit court resentenced Jones to life in prison without parole. Brett appealed to the Mississippi Court of Appeals, which rejected his argument to reverse the sentence. The state supreme court then held oral arguments for the case before dismissing it. Jones petitioned the U.S. Supreme Court for review.[2]
  • The issue: The case concerned sentencing of juveniles to life imprisonment without parole.
  • The questions presented: "Whether the 8th Amendment requires the sentencing authority to make a finding that a juvenile is permanently incorrigible before imposing a sentence of life without parole."[3]
  • The outcome: The court affirmed the decision of the Mississippi Court of Appeals in a 6-3 ruling, holding that the U.S. Supreme Court's rulings in Miller v. Alabama and Montgomery v. Louisiana do not require a sentencing judge to make a separate finding that a juvenile convicted of murder is permanently incorrigible before imposing a sentence of life without parole. A discretionary sentencing system where the sentencer can take the defendant's age into account is constitutionally sufficient.[1]


    • You can review the lower court's opinion here.

    Timeline

    The following timeline details key events in this case:

    Background

    Brett Jones, the petitioner, turned 15 years old in July of 2004. Three weeks later, he killed his grandfather, Bertis Jones, during an argument by stabbing Bertis eight times. In Lee County Circuit Court, a jury rejected Brett's argument of self-defense and found Brett guilty of murder. He was sentenced to life in prison without parole.[2]

    Following the U.S. Supreme Court's decision in Miller v. Alabama (2012), the Mississippi Supreme Court granted a motion for post-conviction relief, vacated Brett's sentence, and remanded the case for a sentencing rehearing. On April 7, 2015, the Lee County Circuit Court resentenced Jones to life in prison without parole.[2]

    Brett appealed to the Mississippi Court of Appeals. The court of appeals rejected Brett's argument to reverse the sentence. Two judges dissented, saying they would have reversed and remanded the sentence based on the U.S. Supreme Court's decision in Montgomery v. Louisiana (2016).[2]

    The Mississippi Supreme Court accepted a petition to review the court of appeals' ruling. After hearing oral argument, the state supreme court dismissed the petition. Four judges dissented, arguing Brett's case should be remanded with instructions to sentence him to life in prison with the possibility of parole.[2]

    Brett filed a petition for review with the U.S. Supreme Court. In the petition, Brett argued (1) the issue divided state supreme courts and (2) that without a requirement to find permanent incorrigibility before sentencing juveniles to life in prison without parole, SCOTUS precedent in Miller and Montgomery would "lose its force as a rule of law."[2]

    SCOTUS precedent

    In 2012, SCOTUS held in Miller v. Alabama that juvenile defendants could not be sentenced to life imprisonment without parole. The court held such a sentence violated the 8th Amendment, which bans cruel and unusual punishment. In 2016, SCOTUS held in Montgomery v. Louisiana that the rule it established in Miller was retroactive and applied to all juveniles except "those whose crimes reflect permanent incorrigibility."[4][5]

    Questions presented

    The petitioner presented the following questions to the court:[3]

    Questions presented:
    “ Whether the 8th Amendment requires the sentencing authority to make a finding that a juvenile is permanently incorrigible before imposing a sentence of life without parole.[6] ”

    Oral argument

    Audio

    Audio of oral argument:[7]



    Transcript

    Outcome

    The court affirmed the decision of the Mississippi Court of Appeals in a 6-3 ruling, holding that the U.S. Supreme Court's rulings in Miller v. Alabama and Montgomery v. Louisiana do not require a sentencing judge to make a separate finding that a juvenile convicted of murder is permanently incorrigible before imposing a sentence of life without parole. A discretionary sentencing system where the sentencer can take the defendant's age into account is constitutionally sufficient.[1] Justice Brett Kavanaugh delivered the majority opinion of the court and Justice Clarence Thomas wrote a concurrence. Justice Sonia Sotomayor wrote a dissenting opinion joined by Justices Stephen Breyer and Elena Kagan.

    Opinion

    In the court's majority opinion, Justice Brett Kavanaugh wrote:[1]

    “ Jones’s argument that the sentencer must make a finding of permanent incorrigibility is inconsistent with the Court’s precedents. In Miller, the Court mandated “only that a sentencer follow a certain process—considering an offender’s youth and attendant characteristics—before imposing” a life-without-parole sentence. Id., at 483. And in Montgomery v. Louisiana, which held that Miller applies retroactively on collateral review, the Court flatly stated that “Miller did not impose a formal factfinding requirement” and added that “a finding of fact regarding a child’s incorrigibility ... is not required.” ...


    In the wake of Miller, the Mississippi Supreme Court concluded that Miller applied retroactively on state collateral review. In Jones’s case, the State Supreme Court ordered a new sentencing hearing where the sentencing judge could consider Jones’s youth and exercise discretion in selecting an appropriate sentence. ...

    At the end of the hearing, the sentencing judge acknowledged that he had discretion under Miller to impose a sentence less than life without parole. But after considering the factors “relevant to the child’s culpability,” App. 149, the judge determined that life without parole remained the appropriate sentence for Jones, id., at 152. ...

    To be clear, our ruling on the legal issue presented here should not be construed as agreement or disagreement with the sentence imposed against Jones. ... Determining the proper sentence in such a case raises profound questions of morality and social policy. The States, not the federal courts, make those broad moral and policy judgments in the first instance when enacting their sentencing laws. ...

    Under our precedents, this Court’s more limited role is to safeguard the limits imposed by the Cruel and Unusual Punishments Clause of the Eighth Amendment. The Court’s precedents require a discretionary sentencing procedure in a case of this kind. The resentencing in Jones’s case complied with those precedents because the sentence was not mandatory and the trial judge had discretion to impose a lesser punishment in light of Jones’s youth. ...

    We affirm the judgment of the Mississippi Court of Appeals.[6]

    		”
    —Justice Brett Kavanaugh

    Concurring opinion

    In his concurring opinion, Justice Clarence Thomas wrote:

    “ The Court correctly holds that the Eighth Amendment does not require a finding that a minor be permanently incorrigible as a prerequisite to a sentence of life without parole. But in reaching that result, the majority adopts a strained reading of Montgomery v. Louisiana, 577 U. S. 190 (2016), instead of outright admitting that it is irreconcilable with Miller v. Alabama, 567 U. S. 460 (2012)—and the Constitution. The better approach is to be patently clear that Montgomery was a “demonstrably erroneous” decision worthy of outright rejection. Gamble v. United States, 587 U. S. ___, ___ (2019) (THOMAS, J., concurring) (slip op., at 2).[6] ”
    —Justice Clarence Thomas

    Dissenting opinion

    In the dissenting opinion, Justice Sonia Sotomayor wrote:

    “ Today, the Court guts Miller v. Alabama, 567 U. S. 460 (2012), and Montgomery v. Louisiana, 577 U. S. 190 (2016). Contrary to explicit holdings in both decisions, the majority claims that the Eighth Amendment permits juvenile offenders convicted of homicide to be sentenced to life without parole (LWOP) as long as “the sentence is not mandatory and the sentencer therefore has discretion to impose a lesser punishment.” Ante, at 1. In the Court’s view, a sentencer never need determine, even implicitly, whether a juvenile convicted of homicide is one of “those rare children whose crimes reflect irreparable corruption.” Montgomery, 577 U. S., at 209. Even if the juvenile’s crime reflects “‘unfortunate yet transient immaturity,’” Miller, 567 U. S., at 479, he can be sentenced to die in prison. ...


    The Court rests its conclusion on Montgomery’s modest statement that “Miller did not impose a formal factfinding requirement,” and so “a finding of fact regarding a child’s incorrigibility . . . is not required.” 577 U. S., at 211. This statement is the linchpin of the Court’s opinion. See ante, at 2, 5, 7, 11–14. As the Court quietly admits in a footnote, however, Montgomery went on to clarify that the fact “[t]hat Miller did not impose a formal factfinding requirement does not leave States free to sentence a child whose crime reflects transient immaturity to life without parole. To the contrary, Miller established that this punishment is disproportionate under the Eighth Amendment.” Montgomery, 577 U. S., at 211; see ante, at 7–8, n. 2 (quoting the same). ...

    What is necessary ... is “that a sentencer decide whether the juvenile offender before it is a child whose crimes reflect transient immaturity or is one of those rare children whose crimes reflect irreparable corruption.” Tatum v. Arizona, 580 U. S. ___, ___ (2016) (SOTOMAYOR, J., concurring in decision to grant, vacate, and remand) (slip op., at 3) (internal quotation marks omitted). That is all petitioner Brett Jones seeks. ...

    Rather than read Miller and Montgomery fairly, the Court reprises Justice Scalia’s dissenting view in Montgomery that Miller requires only a “youth-protective procedure.” 577 U. S., at 225 (emphasis deleted). Justice Scalia’s view did not prevail, however. Montgomery’s interpretation of Miller is binding precedent, just as Miller itself is. ...

    The question is whether the State, at some point, must consider whether a juvenile offender has demonstrated maturity and rehabilitation sufficient to merit a chance at life beyond the prison in which he has grown up. See Graham, 560 U. S., at 79. For most, the answer is yes.[6]

    		”
    —Justice Sonia Sotomayor

    Text of the opinion

    Read the full opinion here.

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 Supreme Court of the United States, Jones v. Mississippi, decided April 22, 2021
    2. ↑ 2.0 2.1 2.2 2.3 2.4 2.5 Supreme Court of the United States, Jones v. Mississippi, "Petition for a writ of certiorari," accessed March 9, 2020
    3. ↑ 3.0 3.1 Supreme Court of the United States, Jones v. Mississippi, "Questions presented," accessed March 9, 2020
    4. ↑ The New York Times, "Supreme Court to Consider When Juveniles May Get Life Without Parole," March 9, 2020
    5. ↑ Supreme Court of the United States, Montgomery v. Louisiana, decided January 25, 2016
    6. ↑ 6.0 6.1 6.2 6.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ Supreme Court of the United States, "Oral Argument - Audio," accessed November 9, 2020
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