Summary of Argument

On October 3, 2012, 16-year-old Appellant Blake Layman, 17-year-old Appellant Levi Sparks, 21-year-old Danzele Johnson, and two other teens decided to break into a house in Elkhart, Indiana. The five were not armed and thought the house was vacant. Tragically, not only was the home occupied, but the homeowner shot and killed Mr. Johnson. Though not the shooter, Appellants were convicted of murder under Indiana's felony murder statute. Ind. Code. §135-42-1-1(2). Appellant Layman, who suffered a gunshot wound himself, was sentenced to 55 years in prison, and Appellant Sparks, who never even entered the home, received a 50-year sentence.

The trial court's broad application of Indiana's felony murder statute to juvenile offenders conflicts with U.S. Supreme Court precedent, as well as established research on adolescent development and brain science. Compared with adults, children and teenagers are less able to perceive and assess risks. They are less capable decision-makers than adults as they are more impulsive, less risk-averse, and have difficulty assessing the consequences of their actions, often prioritizing short-term rewards over any potential long-term negative consequences.

This Court should bar the application of Indiana's felony murder statue to juveniles in light of the prevailing and uncontroverted scientific research about adolescent offending. In the alternative, the court should adopt a presumption against imposing Indiana's felony murder statute on juvenile offenders who do not kill the victim, intend to kill the victim, or actually foresee that the victim might be killed in the course of the felony. At a minimum, Indiana should adopt an "agency" approach for juvenile offenders and hold that the felony murder doctrine does not apply if the person who causes the death is not the juvenile or one of his accomplices. Finally, if convicted of felony murder, juvenile offenders' sentences must be based on their own actions and culpability rather than consequences of their actions that they, as adolescents with poor risk-assessment skills, are unlikely to foresee.

Summary of Argument

The case of Layman and Sparks v. State presents a compelling argument against the application of Indiana's felony murder statute to juvenile offenders. The appellants, Blake Layman and Levi Sparks, were convicted of murder under the felony murder statute despite not being the shooter and one not even entering the home. This conviction stemmed from their participation in a break-in, which resulted in the unintentional death of a homeowner.

The trial court's broad interpretation of the felony murder statute in this case contradicts established legal precedent and scientific understanding of adolescent development. The U.S. Supreme Court has recognized the unique cognitive and developmental characteristics of juveniles, which distinguish them from adults and necessitate a different legal approach. Research consistently demonstrates that adolescents possess a reduced capacity for risk assessment, decision-making, and foresight compared to adults. They often prioritize immediate gratification over long-term consequences, making them more prone to impulsive behaviors and less capable of anticipating the potential outcomes of their actions.

Therefore, the application of the felony murder statute to juveniles like Layman and Sparks, who lack the cognitive maturity to fully grasp the gravity of their actions and their potential consequences, raises significant concerns about fairness and proportionality. This Court should consider the following:

• Barring application of the felony murder statute to juveniles. This would ensure that adolescents are not held to the same legal standard as adults, considering their unique developmental limitations.

• Adopting a presumption against applying the felony murder statute to juveniles who do not directly kill, intend to kill, or foresee the victim's death. This presumption would reflect the scientific understanding of adolescent development and mitigate the risk of disproportionate punishment.

• Adopting an "agency" approach for juvenile offenders. This approach would limit the application of felony murder to cases where the juvenile or their accomplice directly causes the death.

• Sentencing juvenile offenders based on their own actions and culpability. This would ensure that sentences are commensurate with the individual's level of responsibility and not simply a reflection of unforeseen consequences.

In conclusion, this case presents a crucial opportunity to address the problematic application of the felony murder statute to juveniles. By incorporating the latest scientific understanding of adolescent development into legal decision-making, this Court can ensure that the legal system appropriately addresses the unique challenges faced by juvenile offenders.

Summary of Argument

This case examines the application of Indiana's felony murder statute to juvenile offenders. The Appellants, Blake Layman and Levi Sparks, were convicted of murder under the statute despite not being the shooter and not having intended to kill the homeowner. The court's broad application of the statute to juveniles is being challenged on the grounds that it contradicts established research in adolescent development and brain science.

The argument hinges on the understanding that adolescents, due to their developmental stage, are less capable than adults of assessing risks and making sound decisions. Their impulsivity and lack of risk aversion, coupled with their difficulty in predicting the consequences of their actions, make them more susceptible to committing acts that result in unintended consequences.

The petitioners advocate for a reassessment of the application of Indiana's felony murder statute to juveniles. They propose several alternatives, including a presumption against applying the statute to juveniles who did not directly cause the death, an "agency" approach that limits the statute's application to those directly involved in the killing, and a sentencing framework that accounts for the juvenile's individual culpability, considering their limited capacity for risk assessment.

Summary of Argument

In 2012, a group of teenagers, including Blake Layman and Levi Sparks, attempted to burglarize a house in Indiana. The house was occupied, and the homeowner fatally shot one of the teenagers, Danzele Johnson. Although Layman and Sparks weren't the shooter, they were convicted of murder under Indiana's felony murder law. This law allows someone to be charged with murder if a death occurs during the commission of another crime, even if they didn't directly cause the death. Layman, who was shot during the incident, received a 55-year prison sentence, and Sparks, who never even entered the house, was sentenced to 50 years.

This case raises important questions about how the law should treat teenagers. Scientific research shows that teenagers' brains are still developing and that they are more impulsive and less capable of understanding the consequences of their actions than adults. Applying the felony murder law to teenagers who didn't intend to kill anyone or foresee that a death might occur may be unfair, especially considering their limited ability to fully grasp the risks of their actions.

This case argues that Indiana's felony murder law should not be applied to teenagers, or at least that it should be applied with caution. The case calls for a review of sentencing practices to ensure that teenagers are held accountable for their own actions, but not unfairly punished for consequences they could not fully anticipate.

Summary of Argument

A group of teenagers, including Blake Layman and Levi Sparks, broke into a house thinking it was empty. The home-owner shot and killed one of the teenagers, Danzele Johnson. Even though Layman and Sparks didn't shoot anyone, they were found guilty of murder under a law called the felony murder statute. This law means that if someone dies during a crime, everyone involved can be charged with murder. Layman, who was also shot, received a 55-year prison sentence, and Sparks, who never even entered the house, was sentenced to 50 years.

The court should consider that teenagers are still learning and growing, and they might not fully understand the risks of their actions. Research shows that young people are more impulsive and less careful than adults. So, the court should change the way the felony murder law applies to teenagers.

They could make it harder to charge a teenager with murder if they didn't directly kill someone, or if they didn't even know someone could get hurt. If a teenager is found guilty of felony murder, their sentence should be based on what they did, not just the bad things that happened as a result.