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Supreme Court Rules on Retroactivity of Miller v. Alabama

The Supreme Court’s prior decision in Miller v. Alabama, holding that sentencing juveniles to life without parole violates the Cruel and Unusual Punishments Clause, is a substantive constitutional rule that must be applied retroactively on state collateral review (unlike a procedural rule, which need not be enforced retroactively). 

Enforcing a penalty barred by the Constitution is by definition unlawful. States may remedy the violation by extending parole eligibility to juvenile offenders; resentencing is not required. See: Montgomery v. Louisiana, 136 S.Ct. 718 (2016).  

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Related legal case

Montgomery v. Louisiana