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State ex rel. Hauser v. State

Citations: 146 So. 3d 202; 2014 La. LEXIS 1684; 2014 WL 3858550Docket: No. 2013-KH-2028

Court: Supreme Court of Louisiana; July 31, 2014; Louisiana; State Supreme Court

Narrative Opinion Summary

In State v. Tate, 2012-2763, the Louisiana Supreme Court held that the ruling in Miller v. Alabama, which addresses the constitutionality of mandatory life sentences for juvenile offenders, does not apply retroactively to sentences imposed before the Miller decision. Chief Justice Johnson dissents, arguing that Miller established a new substantive rule of criminal procedure that should be applied retroactively to juvenile offenders sentenced prior to the Supreme Court's ruling.

Legal Issues Addressed

Dissent on Retroactivity of New Substantive Rules

Application: Chief Justice Johnson argued that the new substantive rule established by Miller v. Alabama should be applied retroactively to juvenile offenders who were sentenced before the ruling.

Reasoning: Chief Justice Johnson dissents, arguing that Miller established a new substantive rule of criminal procedure that should be applied retroactively to juvenile offenders sentenced prior to the Supreme Court's ruling.

Non-Retroactivity of Miller v. Alabama

Application: In State v. Tate, the court determined that the ruling in Miller v. Alabama does not have retroactive effect on sentences imposed before the decision was made.

Reasoning: The Louisiana Supreme Court held that the ruling in Miller v. Alabama, which addresses the constitutionality of mandatory life sentences for juvenile offenders, does not apply retroactively to sentences imposed before the Miller decision.