Florida’s Second District Court of Appeals decided last week that the United States Supreme Court’s 2012 decision in Miller v. Alabama barring mandatory life imprisonment without parole sentences for children applies retroactively to cases on collateral review.
Florida law provides that a decision applies retroactively to cases that have already become final if the decision is a “development of fundamental significance.” A decision that take away the state’s power to impose certain penalties qualifies as such a development. The court reasoned that the Miller decision, by invalidating Florida’s mandatory life-without-parole sentencing scheme, “has dramatically disturbed the power of the State of Florida to impose a nondiscretionary sentence of life without parole on a juvenile convicted of a capital felony,” and therefore applies retroactively.
The court further found that Miller is “of sufficient magnitude to necessitate retroactive application” because “it is a significant change in the law that forbids sentencing authorities from ignoring a juvenile’s ‘diminished culpability and heightened capacity for change.'”
Florida has one of the nation’s highest populations of juveniles serving mandatory life-without-parole sentences, but the court held that applying Miller retroactively to all defendants sentenced to life as juveniles “would have little effect on the administration of justice” and will not place an onerous burden on the courts.