In Miller v. Alabama, (2012) 567 U.S. 460, the issue arose in two companion cases, both involving 14-year-old defendants, Jackson and Miller, who were convicted of murder and sentenced to LWOP. (Ibid.) Jackson's case arose on appeal from the dismissal of a petition for writ of habeas corpus; Miller's case arose on direct appeal. In Miller, the court explained that its prior cases had "established that children are constitutionally different from adults for purposes of sentencing." The Miller court summarized its holding as follows: "Mandatory life without parole for a juvenile precludes consideration of his or her chronological age and its hallmark features--among them, immaturity, impetuosity, and failure to appreciate risks and consequences. It prevents taking into account the family and home environment that surrounds him or her--and from which he or she cannot usually extricate himself or herself--no matter how brutal or dysfunctional. It neglects the circumstances of the homicide offense, including the extent of his or her participation in the conduct and the way familial and peer pressures may have affected him or her. Indeed, it ignores that he or she might have been charged and convicted of a lesser offense if not for incompetencies associated with youth--for example, his or her inability to deal with police officers or prosecutors (including on a plea agreement) or his or her incapacity to assist his or her own attorneys. . And finally, this mandatory punishment disregards the possibility of rehabilitation even when the circumstances most suggest it."