Martin v. Symmes

Juvenile Law Center filed an amicus brief in support of the Motion to File a Second or Successive Petition Pursuant to 28 U.S.C. § 2254 filed by private counsel, on behalf of Martin, who was sentenced to life without parole as a juvenile in state court in Minnesota and now seeks to have his sentence revisited in light of the United States Supreme Court’s ruling in Miller v. Alabama, which banned mandatory life without parole sentences for juveniles. Our brief was filed on behalf of a large group of advocacy organizations.

Since Martin had already filed a federal habeas petition before Miller was decided, he now seeks to have his sentence revisited. Our brief argues that Martin is entitled to relief based on the second exception to the prohibition on filing a second or successive habeas petition, which allows a subsequent petition when it is premised on “a new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court, that was previously unavailable.”  28 U.S.C. § 2255. 

Juvenile Law Center specifically argued that first, the Court unambiguously resolved this question when it granted relief to Kuntrell Jackson, petitioner in Jackson v. Hobbs; that second, Miller announced a substantive rule, which is consistent with the Supreme Court’s interpretation of the Eighth Amendment in light of its evolving understanding and appreciation of the significance of child and adolescent development, which is a substantive ruling and thus merits retroactive application; and that third, because the Miller Court found a violation of the Eighth Amendment, the rule announced necessarily must provide retroactive relief, as categorically, any Eighth Amendment decision barring a particular sentence must be retroactive, including Miller; and finally, that even assuming the rule is procedural, Miller is a “watershed rule[] of criminal procedure” under Teague v. Lane, 489 U.S. 288, 300 (1989).  

For each of these reasons, we argued that the holding in Miller applies retroactively to inmates, such as Petitioner, serving mandatory life without parole sentences for crimes committed as juveniles who have exhausted both direct and collateral appeal rights and seek to file a successive habeas petition.

On April 6, 2015, the United States Eighth Circuit Court of Appeals ruled that the United States Supreme Court's decision in Miller was not retroactively applicable to cases on collateral review.