Jones v. Mississippi

Justia Summary

A Mississippi jury convicted Jones of murder for killing his grandfather when Jones was 15 years old. Under Mississippi law, murder carried a mandatory sentence of life without parole. That sentence was affirmed on appeal. The Supreme Court subsequently held, in Miller v. Alabama, that the Eighth Amendment permits a life-without-parole sentence for a defendant who committed homicide when he was under 18 only if the sentence is not mandatory and the sentencer has the discretion to impose a lesser punishment. The Mississippi Supreme Court ordered that Jones be resentenced. The judge at resentencing acknowledged that he had discretion under Miller to impose a sentence less than life without parole but determined that life without parole remained the appropriate sentence. The Supreme Court had recently held (Montgomery v. Louisiana) that Miller applied retroactively on collateral review. The Mississippi Court of Appeals rejected Jones’s argument that, under Miller and Montgomery, a sentencer must make a separate factual finding that a murderer under 18 is permanently incorrigible before sentencing the offender to life without parole.

The Supreme Court affirmed. In the case of a defendant who committed homicide when he was under 18, Miller and Montgomery do not require the sentencer to make a separate factual finding of permanent incorrigibility before sentencing the defendant to life without parole; a discretionary sentencing system is both constitutionally necessary and constitutionally sufficient. The cases require consideration of an offender’s youth but not any particular factual finding nor an on-the-record sentencing explanation with an “implicit finding” of permanent incorrigibility before sentencing a murderer under 18 to life without parole. Jones’s resentencing complied with Miller and Montgomery because the sentencer had discretion to impose a sentence less than life without parole in light of Jones’s youth.

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