concluding the rule in Miller is procedural and not substantive because first, the rule does not categorically ban life imprisonment without parole for juveniles convicted of homicide; second, relevant federal decisions, i.e. Craig, have concluded Miller is procedural; and third, unlike Ring v. Arizona, 536 U.S. 584, 122 S.Ct. 2428, 153 L.Ed.2d 556 (2002), Miller does not announce a new element that must be proven
How later courts described this case
- concluding the rule in Miller is procedural and not substantive because first, the rule does not categorically ban life imprisonment without parole for juveniles convicted of homicide; second, relevant federal decisions, i.e. Craig, have concluded Miller is procedural; and third, unlike Ring v. Arizona, 536 U.S. 584, 122 S.Ct. 2428, 153 L.Ed.2d 556 (2002), Miller does not announce a new element that must be proven
- reasoning that the Miller rule is procedural, inter alia, because it "does not eliminate the power of the State to impose the punishment of life imprisonment without the possibility of release upon a juvenile offender who has committed a homicide offense.”
- concluding that Miller does not establish a watershed rule because it focuses exclusively on sentencing and does not alter bedrock procedural elements essential to fairness of a proceeding
- holding that Miller v. Alabama, 567 U.S. 460, 132 S.Ct. 2455, 183 L.Ed.2d 407 (2012), did not apply retroactively to cases on collateral review
Written by the judges who cited it.
Later courts went against this
Overruled by Prentis Cordell Jackson v. State of Minnesota, 2016 Minn. LEXIS 485 (2016)
Davis v. Michigan, — U.S. -, 136 S.Ct. 1356, 194 L.Ed.2d 339 (2016); Chambers v. State, 831 N.W.2d 311, 328-31 (Minn. 2013), overruled by Jackson v. State, 883 N.W.2d 272, 279 (Minn. 2016).
The opinion
WRIGHT, Justice
(concurring).
I join in the concurrence of Justice G. Barry Anderson.