In June 2012, the United States Supreme Court ruled 5-4 in Miller v. Alabama that it is unconstitutional to sentence a juvenile ~ someone who was under the age of 18 at the time the crime was committed ~ to a mandatory life without parole sentence. The Miller court decision did not determine if the decision should be applied retroactively and left that question to the states to answer. In 2013, the Pennsylvania Supreme Court decided in Commonwealth v. Cunningham that Miller was not retroactive. In January 2016, the United States Supreme Court disagreed. The court ruled in Montgomery v. Louisiana that Miller should be applied retroactively and should apply to cases decided prior to the 2012 court ruling. The Montgomery court ruling means that juvenile offenders previously sentenced to mandatory life without parole can seek to be resentenced by the trial court. The Pennsylvania Supreme Court has issued a ruling on the “juvenile lifer” issue which gives a bit of clarity on the procedural path these types of cases will take.