Summary of Argument

In Sullivan, the state court decision rests on a state ground that is independent of the question petitioner asks this Court to decide. The only federal premise of the state court’s decision is the clearly correct statement that Roper v. Simmons did not establish a new right regarding noncapital sentences. Under Fox Film Corp. v. Muller, a clearly correct federal premise to a court ruling on state law is insufficient to give this court jurisdiction to review a different federal question not necessary to the judgment. The developmental psychology research cited in the brief of the mental health amici does not support the rule petitioners seek. On the contrary, that research supports the conclusion that teenagers are not a homogenous mass, and courts can and should distinguish the differences among them. Some teens engage in significant illegal behavior only in adolescence and are likely to desist in young adulthood. Others are life-course persistent offenders who are likely to victimize others into middle age if we let them. The latter group is distinguished by the length of antisocial behavior and by the commission of crimes of violence, the same factors courts typically use in determining sentences.

Summary of Argument

The decision rendered by the state court in Sullivan is predicated upon a state ground that is distinct from the federal question raised by the petitioner. The state court's sole reliance on federal law is its acknowledgment of the holding in Roper v. Simmons, which established that the execution of minors violates the Eighth Amendment. However, this premise does not extend to noncapital sentencing.

According to the precedent established in Fox Film Corp. v. Muller, the presence of a correct federal premise in a state court ruling does not confer jurisdiction upon the Supreme Court to review a separate federal question that was not essential to the judgment.

The developmental psychology research cited by the mental health amici does not provide support for the rule sought by the petitioners. Instead, this research suggests that adolescents are not a monolithic group and that courts should consider their individual differences. It highlights that some adolescents engage in criminal behavior only during adolescence and are likely to desist as they mature, while others exhibit persistent antisocial behavior that may continue into adulthood. The latter group can be distinguished by the duration and severity of their criminal conduct, factors that are commonly used in sentencing determinations.

Summary of Argument

In the Sullivan case, the state court's decision was based on a state law that was separate from the issue that the petitioner wanted the Supreme Court to address. The only federal idea that the state court used was the accurate statement that the Roper v. Simmons case did not create a new right for non-death penalty sentences.

According to the Fox Film Corp. v. Muller case, a correct federal idea that is used in a court ruling on state law is not enough to allow the Supreme Court to review a different federal issue that was not required for the decision.

The research on developmental psychology that was mentioned by mental health experts does not support the rule that the petitioners are asking for. Instead, this research shows that teenagers are not all the same and that courts should be able to tell the difference between them.

Some teenagers only commit serious crimes when they are young and are likely to stop when they become young adults. Others are more likely to continue committing crimes into middle age. The second group is different because they have a longer history of antisocial behavior and have committed violent crimes. These are the same factors that courts often use to decide on sentences.

Summary of Argument

In the Sullivan case, the state court made a decision based on a state law that was separate from the issue that the person involved wanted the higher court to decide.

The only thing the state court said about federal law was that a previous court case, Roper v. Simmons, did not create a new rule about sentences for crimes that don't involve the death penalty. This is a correct statement.

According to a rule from another court case, Fox Film Corp. v. Muller, just because a court makes a correct statement about federal law doesn't mean that a higher court can review a different federal issue that wasn't part of the original decision.

The research on how teenagers' brains develop, which was mentioned by some mental health experts, doesn't support the rule that the person in the Sullivan case wanted.

In fact, this research shows that teenagers are not all the same. Some teens only commit serious crimes when they are teenagers and are likely to stop when they become young adults. Others are more likely to continue committing crimes into middle age.

The second group is different because they have been committing crimes for a longer time and have committed violent crimes. These are the same things that courts usually consider when deciding on sentences.

Summary of Argument

In a case called Sullivan, the state court made a decision based on a state law that was separate from the question being asked to a higher court.

The only thing the state court said about federal law was that a previous case called Roper v. Simmons did not create a new rule about punishments for crimes that are not the death penalty.

According to a case called Fox Film Corp. v. Muller, if a state court makes a decision based on state law, even if it mentions a federal law correctly, that's not enough for a higher court to review a different federal question that wasn't part of the decision.

Researchers who study mental health say that teenagers' brains are still developing. But this research doesn't mean that all teenagers should be treated the same. In fact, the research shows that teenagers are different from each other. Some teenagers only do bad things when they're young and stop when they get older. Others keep doing bad things for a long time, even into adulthood.

The second group of teenagers is different because they have been doing bad things for a long time and have hurt other people. Courts use these things to decide how long someone should be punished.