mr. plaisance. >> mr. chief justice and may it please the court. miller versus alabama established a new substantive rule prohibiting mandatory life without parole for juveniles which should be applied retro actively. this court has jurisdiction to hear henry montgomery's claim because the louisiana supreme court relied exclusively on federal juris prudence. in miller this court held that mandatory life in prison was unconstitutional. it also held that life in prison would be an uncommon, rash sentence even today. >> isn't it just like a state saying, we have a fourth amendment, and the federal constitution has a fourth amendment. we are going to apply our own constitution, but in applying it, we will follow the federal precedent. i think we would say, in that case, the case has been decided on the state constitutional ground, even though the state court, in interpreting that ground, is looking to federal decisions. >> in this case, your honor, the louisiana supreme court did not state that it was exercising any independent grounds at all. under mi