Louisiana v. Aaron G. Hauser

A juvenile may be sentenced to life in prison without the possibility of parole if the juvenile’s “crimes reflect irreparable corruption.” Montgomery v. Louisiana, 136 S. Ct. 718, 726 (2016); Miller v. Alabama, 567 U.S. 460, 479 (2012). Respondent Aaron Hauser committed a premeditated, double homicide when he was 17 years old. He was sentenced to life in prison without parole, and he has served more than 35 years of that sentence. After an evidentiary hearing to consider whether to reform Hauser’s sentence and grant him the possibility of parole, the state trial court concluded that, based on the nature of Hauser’s crime, he was “one [of] the worst offenders” in one of “the worst cases.” It ordered Hauser to continue serving his life sentence without the possibility of parole. The state appellate court reversed. Relying heavily on Hauser’s clean 35-year prison record, the appellate court concluded that, in light of Montgomery and Miller, the trial court erred by denying Hauser parole eligibility. *** Does a sentencing court run afoul of Montgomery and Miller by weighing the heinous facts of a juvenile’s violent crime more heavily than any subsequent evidence of rehabilitation in prison when determining whether the juvenile’s “crimes reflect irreparable corruption”?