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In a case revisiting its landmark 2012 juvenile justice decision in Miller v. Alabama, on Jan. 25, 2016, the U.S. Supreme Court ruled in Montgomery v. Louisiana that its holding in Miller prohibiting mandatory life without parole for juveniles is a substantive rule of constitutional law and therefore retroactive in cases of state collateral review. Indeed, the Court emphasized its finding in Miller that it is a violation of the Eighth Amendment’s prohibition on “cruel and unusual” punishment to mandatorily impose life without parole sentencing for juveniles. By its ruling, the Court resolves what had become a split in the state courts.
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