Jones v. Mississippi: Sweeping Away the Due Process Protections of Juvenile Offenders

The U.S. Supreme Court’s pronouncement in Jones v. Mississippi raises questions about whether states will adequately adhere to the fundamental fairness principles of constitutional due process. The current juvenile sentencing procedures center on Miller v. Alabama, in which the Court struck down mandatory life-without-parole statutes applicable to juveniles. But in the post-Miller era, state legislatures and courts have struggled with how to apply the Miller Court’s holding. Ultimately, the Jones Court eliminated procedural due process rights for the criminal system’s most vulnerable class.

But while procedural due process in the criminal sentencing context is not well defined as is, the holding in Jones does not even meet a broad fundamental fairness threshold. This article argues that Jones v. Mississippi undermines the procedural due process rights afforded to this category of defendants and how the Jones majority hinders the forward momentum of recognizing rehabilitation as a goal for transferred youth, as required in Graham, Miller, and Montgomery. This article also discusses the standards employed by federal trial courts to minimize bias in a discretionary sentencing system. Finally, this article expounds on the basic frameworks established in state legislatures and courtrooms to fulfill the spirit of Miller v. Alabama—that children are constitutionally different.

Thus, sentencing standards must bend to accommodate this recognition, and possible solutions are proposed to remedy the sentencing challenges presented by Jones.