Miller v. Alabama’s prohibition on mandatory life without parole for juvenile offenders announced a new substantive, not procedural, rule. Miller is therefore retroactive in cases of state collateral review.
SCOTUS
Musacchio v. United States, No. 14-1095, ___ U.S. ___, (Jan. 25, 2016).
Sufficiency of evidence review does not depend on how jury was instructed; it is judged against essential elements of the offense, not against erroneous jury instruction that included an additional element.
Statute of limitations defense was not jurisdictional and therefore could not be raised for the first time on appeal.
Kansas v. Carr, No. 14-449, ___ U.S. ___ (Jan. 20, 2016).
The Eighth Amendment does not require capital-sentencing courts to instruct a jury that mitigating circumstances need not be proved beyond a reasonable doubt. Joint capital-sentencing proceeding did not violate defendants’ Eighth Amendment right to an “individualized sentencing determination.”
Hurst v. Florida, No. 14-7505, ___ U.S. ___ (Jan. 12, 2016).
Florida’s death-penalty statutory scheme, under which judge must find aggravating circumstance justifying death and jury’s sentencing recommendation of death or life without parole is only advisory, violates Sixth Amendment jury right.
Johnson v. United States, No. 13-7120, ___ U.S. ___ (June 26, 2015).
Armed Career Criminal Act (ACCA)’s definition of “violent felony” is unconstitutionally vague as to its residual clause, which covers any felony that “involves conduct that presents a serious potential risk of physical injury to another”; clause leaves uncertainty about how to estimate the risk posed by a crime or how much risk it takes for a crime to qualify as a violent felony. (Overruling James v. United States, 550 U.S. 192 (2007) and Sykes v. United States, 564 U.S. 1 (2011).)