Summary of Argument

In Graham v. Florida, the United States Supreme Court held that sentencing juveniles to life without parole for non-homicide offenses constitutes cruel and unusual punishment. 560 U.S. 48 (2010). The Court reasoned that youth are less culpable than adults because of biological difference in brain development that render youth more immature, more likely to engage in risky behavior, and more vulnerable to external influences like peer pressure. Id. at 91-92. Additionally, because youth brains are still developing well into late adolescence, the Court determined that their personality traits are more transient and capable of change than adult personalities. Id. at 68-69. The undisputed scientific data confirms that youth cannot be expected to act as mature adults.

The Supreme Court clarified and extended the Graham decision in Miller v. Alabama, 132 S. Ct. 2455 (2012). There, the Court found that because youth offenders were less culpable due to the characteristics noted in Graham, imposing mandatory life sentences without the possibility of parole for juvenile homicide offenders constituted cruel and unusual punishment. Taken together, the Court’s decisions in Graham and Miller mandate that when sentencing youth offenders, a court must consider as mitigating factors the characteristics that make youth offenders different.

The Petitioner’s sentence must be vacated because, pursuant to the Graham and Miller framework, youth offenders are less culpable and are entitled to a meaningful opportunity for release. In addition to concluding that Miller may be applied retroactively, amici respectfully request that the Court provide guidance to the lower courts on how to apply Missouri sentencing statutes in a constitutional fashion so that youth offenders have the opportunity to seek parole and become productive members of society. Providing this constitutionally-mandated opportunity is especially important here, where the Petitioners’ early life was scarred by poverty, despair, and fear.

Summary of Argument

The United States Supreme Court, in Graham v. Florida, ruled that sentencing juveniles to life without parole for non-homicide offenses violates the Eighth Amendment's prohibition on cruel and unusual punishment. The Court reasoned that juveniles, due to their developing brains and susceptibility to external influences, are less culpable than adults. This diminished culpability is rooted in scientific evidence demonstrating the unique developmental trajectory of the adolescent brain. The Court further emphasized that youthful traits, unlike those of adults, are more malleable and subject to change.

Miller v. Alabama extended the Graham framework to encompass mandatory life sentences without parole for juvenile homicide offenders. The Court, drawing on the rationale established in Graham, determined that such sentences are unconstitutional due to the diminished culpability inherent in juvenile offenders. Taken together, Graham and Miller establish that sentencing courts must consider the unique characteristics of youth offenders as mitigating factors.

The petitioner's sentence violates the principles established in Graham and Miller. The petitioner, as a juvenile offender, is less culpable and therefore entitled to a meaningful opportunity for release. Amici urge the Court to provide guidance to lower courts on the proper application of Missouri sentencing statutes to ensure that juvenile offenders have access to parole and the potential for rehabilitation. The Court's guidance is particularly crucial in cases like this, where the petitioner's early life was marked by adversity.

Summary of Argument

The United States Supreme Court ruled in Graham v. Florida that sentencing juveniles to life without parole for non-homicide offenses violates the Eighth Amendment's prohibition against cruel and unusual punishment. The Court reasoned that juveniles are less culpable than adults because their brains are still developing, making them more impulsive, susceptible to peer pressure, and less capable of mature decision-making.

Subsequently, in Miller v. Alabama, the Court extended this principle to include mandatory life sentences without parole for juvenile homicide offenders. The Court emphasized that the unique characteristics of youth, including their developmental immaturity and potential for rehabilitation, must be considered in sentencing.

The Petitioner in this case argues that their sentence should be vacated because it fails to account for the mitigating factors of their youthfulness. Furthermore, the Petitioner requests that the Court clarify how Missouri sentencing statutes can be applied in a way that is consistent with the constitutional principles established in Graham and Miller. This would ensure that juvenile offenders have a meaningful opportunity for release and the chance to become productive members of society.

Summary of Argument

The Supreme Court ruled in the case of Graham v. Florida that sentencing young people to life in prison without the possibility of parole for crimes other than murder is cruel and unusual punishment. The Court explained that young people are less responsible for their actions than adults because their brains are still developing and they are more susceptible to peer pressure.

The Court extended this ruling in Miller v. Alabama, stating that mandatory life sentences without parole for young people who commit murder are also unconstitutional. These rulings require courts to consider the unique characteristics of young offenders when sentencing them.

The Petitioner's sentence should be overturned because, under the Graham and Miller decisions, young offenders are less culpable and deserve a chance to be released from prison. The Court should provide clear instructions to lower courts on how to apply Missouri sentencing laws in a way that respects these constitutional rights. This is especially important for the Petitioner, whose childhood was marked by poverty and hardship.

Summary of Argument

The Supreme Court said it's not fair to give kids life in prison without a chance to get out for crimes that aren't murder. This is because kids' brains are still developing and they're not as responsible as adults. They're more likely to take risks and be influenced by their friends.

The Court also said that kids' personalities are changing more than adults' and they can learn and grow. They said that since kids are different, judges need to take that into account when deciding on punishments. The Court wants to make sure that kids who commit crimes have a chance to show they can change and become good people. They want to help these kids get a second chance.