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Life Sentence at Seventeen: The Controversy of Mathena v. Malvo in SCOTUS

By: Haig Simitian

· Domestic Policy

In 2002, Lee Malvo and John Allen Muhammad killed 10 people in sniper attacks in Virginia, Maryland, and the District of Columbia. Muhammad was sentenced to death and executed in 2009. Malvo, who was only 17 years old at the time of the attacks, was sentenced to life in prison by judges in Virginia and Maryland. He challenged his Virginia sentences based on two US Supreme Court decisions.

The first case used as a point of argument was in Miller v. Alabama (2012), where the Supreme Court held that “mandatory life without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment’s prohibition on ‘cruel and unusual punishments.’” Four years later, in Montgomery v. Louisiana (2016), the Supreme Court held that its decision in Miller v. Alabama was a “substantive rule of constitutional law” and therefore must be given “retroactive effect” in cases where direct review was complete when Miller v. Alabama was decided.
The key to understanding this supreme court case lies in this “retroactive effect.” Malvo argued that his sentence must be vacated because Montgomery v. Louisiana modified a “substantive rule of constitutional law” and was thus retroactively applied to his own sentencing. Under this reading, sentences that were legal at the time when they were sentenced, as Malvo’s was, must be vacated if they were imposed in violation of the Supreme Court’s new rules (which in this case is that those under the age of 18 at the time of their crimes violates the Eighth Amendment’s prohibition on cruel and unusual punishments). The district court found Malvo’s arguments persuasive and vacated his four sentences of life imprisonment.

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