Summary of Argument

In Miller v. Alabama, 567 U.S. , 132 S. Ct. 2455, 183 L.Ed.2d 407 (2012), the United States Supreme Court held that the mandatory imposition of life without parole sentences on juvenile offenders is unconstitutional. Under current California law, the presumptive sentence for any juvenile age 16 or older convicted of first degree murder with special circumstances is life imprisonment without the possibility of parole. See Cal. Penal Code § 190.5(b). California’s statute effectively imposes life without parole on juveniles in a mandatory fashion, in violation of Miller, as life without parole is the mandatory penalty unless the judge finds justification to deviate from this presumptive penalty. California Penal Code § 190.5(b) therefore fails to impose an individualized sentence as required by Miller, and contradicts Miller’s requirement that juvenile life without parole sentences be uncommon. Further, any life without parole sentence for a juvenile convicted of felony murder is inconsistent with adolescent development and neuroscience research and is unconstitutional pursuant to Miller and Graham v. Florida, 130 S. Ct. 2011 (2010) (holding that a life without parole sentence can never be imposed upon a juvenile when there is no finding that the juvenile either killed or intended to kill). Accordingly, Appellant Andrew Lawrence Moffett’s sentence must be vacated and a new constitutional sentence imposed.

Summary of Argument

In Miller v. Alabama, the Supreme Court declared unconstitutional the mandatory imposition of life without parole sentences for juvenile offenders. California Penal Code § 190.5(b) dictates a presumptive sentence of life imprisonment without parole for juveniles aged 16 or older convicted of first-degree murder with special circumstances. This statute effectively mandates life without parole for juveniles, contravening Miller’s mandate for individualized sentencing and its requirement of uncommon juvenile life without parole sentences. Furthermore, any life without parole sentence for a juvenile convicted of felony murder is incompatible with adolescent developmental and neuroscience research, rendering it unconstitutional under Miller and Graham v. Florida. Therefore, Appellant Andrew Lawrence Moffett’s sentence must be vacated and replaced with a constitutionally compliant sentence.

Summary of Argument

In the case of Miller v. Alabama, the Supreme Court ruled that imposing mandatory life without parole sentences for juvenile offenders is unconstitutional. Currently, California law mandates life imprisonment without parole as the presumptive sentence for any juvenile 16 or older who is convicted of first-degree murder with special circumstances. This law is in direct conflict with Miller because it fails to allow for individualized sentencing and makes life without parole the default penalty, contradicting the ruling that such sentences should be uncommon for juveniles. Moreover, Miller and Graham v. Florida emphasize the importance of considering adolescent development and neuroscience research when sentencing juveniles, especially for felony murder. Consequently, any life without parole sentence imposed on a juvenile convicted of felony murder must be reevaluated in light of these decisions. This case, involving Appellant Andrew Lawrence Moffett, necessitates the vacating of his current sentence and the imposition of a new sentence that adheres to constitutional principles.

Summary of Argument

In the case of Miller v. Alabama, the Supreme Court ruled that it is against the Constitution for judges to automatically sentence young people to life in prison without the possibility of parole.

California law, however, allows for this type of sentence for anyone 16 or older who is convicted of first-degree murder with special circumstances. The Supreme Court’s ruling in Miller suggests that California’s law is unconstitutional because it doesn’t allow judges to consider each case individually and instead forces them to give a life-without-parole sentence unless they have a very specific reason to do otherwise.

This goes against the Miller ruling in two ways. First, Miller says that these types of sentences should be unusual. Second, research shows that young people’s brains are still developing and they are not fully capable of understanding the consequences of their actions. This means that a life-without-parole sentence is not appropriate for someone who committed a crime as a teenager.

In light of these rulings, Andrew Lawrence Moffett’s sentence should be overturned and a new sentence that is consistent with the Constitution should be imposed.

Summary of Argument

The Supreme Court determined in a case called Miller v. Alabama that it's not fair to give kids who commit crimes life in prison without the chance to get out. California's law says that kids 16 or older who commit murder get life in prison without parole, no matter what. That's not okay because it doesn't give the judge a choice. The court said that the law needs to let the judge decide what the right punishment is. It also said that giving kids life without parole is wrong because kids are still growing and changing.