In the 2012 case of Miller v. Alabama, the U.S. Supreme Court ruled it unconstitutional to sentence juvenile offenders to mandatory life sentences without the possibility of patrol. Such sentences, the court held, constitute cruel and unusual punishment.
One reason is that such sentences fail to take into account that people under the age of 18, at the least, are still developing mentally and emotionally. The hallmark features of youth, the court said, include immaturity, impetuosity and a reduced ability to recognize the risks and likely consequences of their actions.
Another reason is that juveniles often make their choices based largely on their home environment. Juveniles are generally not in a position to extricate themselves from their home environments, no matter how dysfunctional or brutal.
Life without parole denies any possibility that the defendant could someday be rehabilitated. Yet we know that people can and do change over time — sometimes merely by maturing.
The Supreme Court not only ruled that juveniles cannot legally be sentenced to life without parole in the future but also that existing sentences must be reconsidered. Around the country, many courts have been working to resentence juvenile lifers — sometimes encountering strong opposition.
Should juvenile lifer Lee Boyd Malvo be resentenced?
Lee Malvo, now 34, was only 17 during the 2002 “D.C. Sniper” incidents in which he played a role. Over the course of two months, snipers shot at people in Washington, D.C., Maryland and Virginia. Those crimes were tied to a crime spree that took place in several states. Overall, the snipers were responsible for 17 deaths and 10 injuries.
John Allen Muhammed, who was 25 years older than Malvo, is said to have brainwashed and groomed the juvenile until he cooperated with the crimes. Malvo admitted working as the “spotter” in many of the shootings and having killed three people. Muhammed was sentenced to death and executed in 2009.
Now, the U.S. Supreme Court has agreed to decide whether Malvo should be resentenced to something less than life without parole.
The question before the court is whether Malvo could be deemed “irreparably corrupt” based on the horrific crimes in which he took part. Or, is it more accurate to say that the crimes represented “the transient immaturity of youth.”
If Malvo weren’t under Muhammed’s direct control, would he have taken part in the murder spree? How much of his involvement was due to a young person’s lack of understanding of the seriousness of his actions? Is there any chance that Malvo could be rehabilitated? Does this really represent a situation where the principles of Miller v. Alabama should not apply?