Martinez v. United States of America

Juvenile Law Center filed an amicus brief in the United States Court of Appeals for the Seventh Circuit on behalf of Emanuel Martinez and Timothy Vallejo, who received mandatory life without parole sentences after pleading guilty to a RICO-murder they committed as teenagers.

Juvenile Law Center’s brief argued that their sentences are unconstitutional pursuant to the United States Supreme Court’s ruling in Miller v. Alabama, which banned mandatory life without parole sentences for juveniles. Before the Seventh Circuit was whether Miller should be given retroactive effect and thus, whether the Appellants should be resentenced following an individualized sentencing hearing.

Juvenile Law Center asserted that Miller applies retroactively to cases like Mr. Martinez and Mr. Vallejo’s, which were final before the decision came down from the U.S. Supreme Court and thus are being considered on habeas review.

Specifically, Juvenile Law Center argued that Miller applies retroactively because it is a substantive rule. Moreover, even if Miller was not a substantive rule, it was a “watershed rule” that must apply retroactively under U.S. Supreme Court precedent. Additionally, we argued that Miller is retroactive because the Eighth Amendment itself requires Miller to apply retroactively. Allowing the date that Mr. Martinez and Mr. Vallejo’s sentences became final to prevent them from benefiting from Miller would be an arbitrary infliction of punishment inconsistent with the Eighth Amendment. Finally, we argued that the government’s interest in finality does not outweigh the Appellants’ interest in just sentences.

The United States Court of Appeals for the Seventh Circuit affirmed the decision of the district court, finding that Mr. Martinez and Mr. Vallejo’s life sentences were not mandatory sentences. Because the court held that the juvenile life without parole sentences were not mandatory, the court did not reach the question of whether Miller applied retroactively.