Jackson v. Hobbs

In Jackson v. Hobbs, the U.S. Supreme Court held that the Eighth Amendment to the U.S. Constitution forbids mandatory life imprisonment without parole sentences for children. Kuntrell Jackson—convicted of capital murder based on events that occurred when he was fourteen years old—was granted resentencing in which his youth could be taken into account. Jackson was ultimately resentenced to twenty years imprisonment and was released from prison on parole in 2017. Dozens of other juvenile offenders have been similarly resentenced based on this case.

On November 18, 1999, Jackson was walking with two other juveniles—fourteen-year-old Derrick Shields and fifteen-year-old Travis Booker—through the Chickasaw Courts housing project in Blytheville (Mississippi County) and began discussing the idea of robbing a local video store. On the way to the store, Jackson became aware that Shields was carrying a shotgun in his coat sleeve. When they arrived at the store, Shields and Booker went in, while Jackson remained outside by the door. Shields pointed the shotgun at the video clerk, Laurie Troup, and demanded that she “give up the money.” Troup told Shields that she did not have any money. A few moments later, Jackson went inside. Shields demanded that Troup give up the money five or six more times, and each time she refused. After Troup mentioned calling the police, Shields shot her in the face. The three boys then fled to Jackson’s house without taking any money.

Jackson was charged with capital murder as an adult even though he was fourteen years old. Jackson’s lawyer moved to transfer his case to juvenile court, but the trial judge denied his motion, and the Arkansas Supreme Court affirmed the denial. A Mississippi County jury found Jackson guilty of capital murder, and he was sentenced to a mandatory term of life imprisonment without parole. The Arkansas Supreme Court affirmed his conviction in 2004.

In 2008, Jackson filed a petition for a writ of habeas corpus listing Ray Hobbs—then director of the Arkansas Department of Correction—as the respondent, arguing that the Eighth Amendment’s ban on cruel and unusual punishment forbade the mandatory imposition of a life-without-parole sentence for a juvenile offender. The Jefferson County Circuit Court dismissed the petition, and Jackson then appealed to the Arkansas Supreme Court. In 2011, the Arkansas Supreme Court affirmed the dismissal, finding that the mandatory imposition of a life-without-parole sentence for a juvenile did not violate the Eighth Amendment.

Jackson then appealed to the U.S. Supreme Court, where his case was joined with the case of Evan Miller, an Alabama inmate who was also convicted of murder and sentenced to a mandatory term of life without parole for a crime committed at age fourteen. The Court heard oral arguments in the cases on March 20, 2012. Bryan Stevenson—founder and executive director of the Equal Justice Initiative (EJI) in Montgomery, Alabama, and author of the bestselling book Just Mercy—argued the case on behalf of both Jackson and Miller.

The Court ruled in Miller v. Alabama and Jackson v. Hobbs in a single joint opinion on June 25, 2012. Building on earlier cases finding that the Eighth Amendment’s ban on cruel and unusual punishment prohibited the death penalty for juveniles and life-without-parole sentences for juvenile non-homicide offenders, the 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.’” While not banning the imposition of life without parole for juvenile offenders outright, the Court found that “occasions for sentencing juveniles to this harshest possible penalty will be uncommon.”

In 2017, the Arkansas General Assembly removed life without parole as a sentencing option for juveniles. Following Miller, roughly five dozen individuals serving terms of life without parole for murders committed as juveniles received resentencing hearings throughout Arkansas. Kuntrell Jackson was resentenced to twenty years and paroled in 2017.

For additional information:
Daniels, Alex. “Arkansas Loses Sentencing Law For Young Killers.” Arkansas Democrat-Gazette, June 26, 2021, pp. 1A, 2A.

Jackson v. State, 359 Ark. 87, 194 S.W.3d. 757 (2004).

Jackson v. State, 2011 Ark. 49, 378 S.W.3d 103.

“Miller v. Alabama and Jackson v. Hobbs.” American Psychological Association. https://www.apa.org/about/offices/ogc/amicus/miller-hobbs (accessed November 4, 2022).

Miller v. Alabama, 567 U.S. 460 (2012).

Michael Kiel Kaiser
Little Rock, Arkansas