Missouri Supreme Court Orders New Sentencing Hearings for Teens Sentenced to Die in Prison


The Missouri Supreme Court vacated the mandatory life imprisonment without parole sentences imposed on a seventeen-year-old and a sixteen-year-old and ordered that a jury must decide the appropriate sentence for them based on their young age and life circumstances.

The court issued two separate decisions on July 30, 2013, applying the United States Supreme Court’s decision in Miller v. Alabama, which bars mandatory life imprisonment without parole sentences for children, to the cases of seventeen-year-old Laron Hart and sixteen-year-old Ladale Nathan, both on direct appeal.

In Hart, the main opinion, the state’s highest court reversed the child’s sentence of life without parole for first-degree murder “because, as in Miller, it was imposed with no individualized consideration of the myriad of factors discussed in the Miller decision.” The court remanded the case for resentencing “in accordance with Miller’s constitutional safeguards requiring the sentencer to consider whether a sentence of life without parole is just and appropriate in light of Hart’s age and the other circumstances surrounding his offense.”

On remand, the court held, “a juvenile offender cannot be sentenced to life without parole for first-degree murder unless the state persuades the sentencer beyond a reasonable doubt that this sentence is just and appropriate under all the circumstances.”

The court rejected “utterly and completely” the State’s argument that it should use severance to allow the sentencer to choose between life without parole and life with parole for first-degree murder, or to mandate life with parole for all juveniles convicted of first-degree murder.

If the State fails to persuade the jury (or judge, if the defendant waives his right to a jury sentencing) that life-without-parole is just and appropriate, the court instructed, the juvenile defendant must be sentenced within the range for second-degree murder, which is ten to thirty years or life with parole.