Missouri recently passed Senate Bill 590 (“SB 590”) in response to these decisions. However, inadequate time, research, and consideration were given to the passage of SB 590, in part because it was rushed through the legislature near the end of the legislative session. As a result, the bill has many shortcomings that must be fixed; this is the primary focus of this Note. Part II of this Note examines the necessary context and background of a handful of Supreme Court decisions pertaining to this issue. Part III discusses the language and likely impact of SB 590. Part III analyzes the issue presented by the Miller decision, highlights how Missouri has failed to adequately address this issue, assesses what other states have done, and suggests what Missouri should do to remedy the shortcomings of SB 590. Part IV discusses the issue of retroactivity presented by the Montgomery decision and offers a suggestion as to what legislative reform Missouri should undertake to accommodate the Montgomery decision. Part V concludes this Note.

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