Mandatory-life-without-parole-for-juvenile-offenders

QUESTIONS PRESENTED : Missouri’s former first-degree murder statute, Section 565.020, RSMo, mandated a sentence of life without parole for any offender who committed the offense as a juvenile. Did this mandatory sentencing scheme skew the sentencing : proceeding as to any non-homicide counts, by rendering the sentences on those counts immaterial, so as not to warrant the presentation of mitigating evidence, argument, or consideration of the defendant’s individualized circumstances, in violation of the Sixth, Eighth, and Fourteenth Amendments to the United States Constitution and thereby create a structural error warranting a new sentencing proceeding? Section 558.047, RSMo 2016, intended to remedy violations of Miller v. Alabama, 567 U.S. 460 (2012), by granting the possibility of parole after twenty-five years to any offender who had received a mandatory sentence of life without parole for the crime of first-degree murder committed as a juvenile. But does this statute truly remedy the Eighth Amendment violation when a defendant can receive consecutive sentences for non-homicide offenses and thus delay any individualized consideration of the offender’s circumstances and any opportunity for release until well into old age? i