Summary of Argument

As life experience, social science, and this Court’s jurisprudence make clear, children are fundamentally different than adults. For that reason, this Court has held that the Eighth Amendment prohibits juvenile offenders from receiving mandatory sentences of life without parole. Miller v. Alabama, 132 S. Ct. 2455, 2469 (2012). Before sentencing a juvenile offender irrevocably to a lifetime in prison, the Eighth Amendment requires an individual evaluation that accounts for the diminished culpability and heightened rehabilitative capacity of youth. Id.

At present, this Court’s precedents permit mandatory sentences of life with the possibility of parole for juvenile offenders, but prohibit mandatory sentences of life without the possibility of parole for juvenile offenders. Amici contend, however, that no meaningful distinction exists in practice between these two types of mandatory punishments. This Court has assumed that the availability of parole mitigates the disproportionate impact of a life sentence by preserving some prospect of eventual release for juvenile offenders. See Montgomery v. Louisiana, 136 S. Ct. 718 (2016). But as amici explain here, the modern parole system provides no meaningful opportunity for rehabilitation-based release to juvenile offenders sentenced to life with parole. Consequently, for both constitutional and practical purposes, a mandatory sentence of life with parole is effectively the same punishment as a mandatory sentence of life without parole.

This Court should grant certiorari to resolve this next logical question in juvenile-sentencing jurisprudence: whether the mere availability of parole resolves the serious constitutional violation created by a state’s imposition of mandatory life sentences on juvenile offenders. In light of the defects of the modern parole system, amici urge this Court to hold that the Eighth Amendment forbids the imposition of any mandatory life sentence, including one with the possibility of parole, on juvenile offenders.

Summary of Argument

The Eighth Amendment to the United States Constitution prohibits the imposition of mandatory life sentences without the possibility of parole for juvenile offenders, based on the understanding that juveniles are fundamentally different from adults. This legal principle stems from the recognition that juveniles exhibit diminished culpability and possess a heightened capacity for rehabilitation compared to their adult counterparts.

While the Court's jurisprudence allows for mandatory sentences of life with the possibility of parole, the practical application of this distinction is questionable. The modern parole system, as amici argue, lacks the necessary mechanisms to provide meaningful opportunities for rehabilitation-based release for juvenile offenders. This effectively renders the two forms of mandatory life sentences functionally equivalent.

The Court should grant certiorari to address this crucial question in juvenile sentencing jurisprudence, specifically the question of whether the mere possibility of parole adequately addresses the constitutional concerns raised by mandatory life sentences imposed on juvenile offenders. Given the deficiencies inherent in the current parole system, amici advocate for a ruling that prohibits the imposition of any mandatory life sentence, including those with the possibility of parole, on juvenile offenders.

Summary of Argument

The court should grant certiorari to address the constitutionality of mandatory life sentences with the possibility of parole for juvenile offenders. The Court's previous rulings, while prohibiting mandatory life without parole, permit mandatory life with parole, assuming that parole mitigates the disproportionate impact of such a sentence.

However, as amici argue, the modern parole system does not provide meaningful opportunities for rehabilitation-based release for juvenile offenders sentenced to life with parole. Therefore, for both practical and constitutional reasons, mandatory life with parole is essentially equivalent to mandatory life without parole.

The Court should recognize this distinction and hold that the Eighth Amendment prohibits any mandatory life sentence, including those with parole, for juvenile offenders.

Summary of Argument

The Supreme Court has ruled that juvenile offenders cannot be sentenced to life in prison without the possibility of parole. This is because the Eighth Amendment prevents cruel and unusual punishment, and juveniles are different from adults in terms of their understanding of consequences and their potential for rehabilitation.

The Court has previously allowed mandatory life sentences with parole for juveniles, but this petition argues that there is no real difference between these sentences and life without parole. Parole systems today do not provide meaningful opportunities for release based on rehabilitation.

This petition asks the Supreme Court to consider whether mandatory life sentences with parole are constitutional for juvenile offenders, given the flaws in the parole system. The petition argues that the Eighth Amendment should prohibit any mandatory life sentence for juveniles, including those with parole possibilities.

Summary of Argument

The Supreme Court has already decided that children are different from adults and that it's wrong to sentence them to life in prison without the chance of getting out. Now, the court needs to decide if it's okay to sentence kids to life in prison with the chance of getting out on parole. The problem is that parole doesn't really work for kids. This means that sentencing a child to life in prison with parole is basically the same as sentencing them to life in prison without parole.

The court should listen to the people who are asking for them to change the law. They should decide that sentencing a child to life in prison, even with the possibility of parole, is against the law.