Summary of Argument

This Court should grant the petition and answer the question explicitly left open by Miller v. Alabama: whether “the Eighth Amendment requires a categorical bar on life without parole for juveniles.” 567 U.S. 460, 479 (2012). The answer to that question is now clearly yes, and the Court should hold that the U.S. Constitution categorically bars life without parole (“LWOP”) sentences for children.

The Court has previously recognized that imposing an LWOP sentence on a child violates the Eighth Amendment’s prohibition against cruel and unusual punishment “for all but the rare juvenile offender whose crime reflects irreparable corruption.” Montgomery v. Louisiana, 136 S. Ct. 718, 734 (2016) (quoting Miller, 567 U.S. at 479-80) (internal quotation marks omitted). Neither courts nor experts can accurately determine at the time of sentencing whether a particular child’s crime reflects “irreparable corruption” as opposed to merely “transient immaturity.” The brains of teenagers and young adults are still developing, a process that continues into the mid-twenties in many cases. It is apparent that any determination about how that process will continue and what its result will be is inherently speculative. In addition, scientific studies confirm that there are no identifiable factors that even psychological experts can examine to accuratelypredict how a child’s or young adult’s character might be reformed. Because of the impossibility of this determination, some lower courts have found any juvenile life without parole sentence violates their state constitutions, while others have reached inconsistent and arbitrary conclusions when reviewing juvenile life-without-parole sentences. It is critical that this Court resolve this question now, before more juveniles are sentenced to life based on unscientific and arbitrary standards.

Summary of Argument

This case presents a critical opportunity for the Court to clarify the Eighth Amendment's prohibition against cruel and unusual punishment as it applies to life without parole sentences for juveniles. The Court should grant the petition and definitively answer the question left unresolved in Miller v. Alabama, holding that the Eighth Amendment categorically prohibits life without parole sentences for children.

The Court has acknowledged in prior decisions that imposing such a sentence on a child violates the Eighth Amendment except in the "rare" case where the crime reflects "irreparable corruption." However, the Court has not explicitly defined "irreparable corruption" nor established a reliable framework for distinguishing between "transient immaturity" and "irreparable corruption." This creates significant ambiguity and potential for inconsistent application of the Miller standard.

The inherent limitations of predicting future behavior, especially for individuals in the midst of significant brain development, makes it impossible to confidently determine at sentencing whether a child's crime signifies "irreparable corruption." Moreover, scientific research consistently indicates that even expert evaluations cannot accurately predict a child's future development and potential for rehabilitation. This uncertainty compels the Court to acknowledge the inherent arbitrariness and potential for injustice associated with imposing life without parole sentences on juveniles.

Lower courts have responded to this ambiguity with varying approaches, leading to inconsistent and potentially arbitrary outcomes. This underscores the need for the Court's intervention to establish a clear, constitutionally sound standard that ensures the Eighth Amendment's protection of juveniles is consistently upheld.

Summary of Argument

The Court should rule that the Eighth Amendment prohibits life without parole (LWOP) sentences for juveniles. The Court has previously acknowledged that such sentences violate the Eighth Amendment for all but the rarest cases of "irreparable corruption," but courts cannot accurately determine whether a juvenile’s crime reflects this level of corruption.

The developing brains of teenagers and young adults make predictions about future character reform inherently speculative. Scientific studies demonstrate that even expert psychologists cannot definitively predict whether a child’s character will be reformed. As a result, courts have struggled to consistently apply the "irreparable corruption" standard. Some courts have declared all juvenile LWOP sentences unconstitutional, while others have reached conflicting and arbitrary conclusions. This inconsistency demands a clear ruling from the Court, ensuring that juveniles are not sentenced to life without parole based on arbitrary and unscientific criteria.

Summary of Argument

The Supreme Court should answer a question it left open in a previous case: whether a life sentence without parole is ever allowed for people who committed crimes as children. The answer is clear: no, it is unconstitutional.

The Court has already said that life without parole is too harsh for most children who commit crimes. They can't tell at the time of the crime whether the child will be permanently bad or just immature. Children's brains are still developing, and this continues into their early twenties. It's impossible to predict how their brains will develop and whether they will change their behavior. Science also shows that even experts can't tell for sure whether a child will change. Because it's impossible to predict, many courts have ruled against life without parole for children, but others haven't been consistent. It's important for the Court to decide this now, so more children don't get life sentences based on guesswork.

Summary of Argument

This case is about whether it’s fair to sentence kids to life in prison without the chance of getting out. The Supreme Court already said that it’s usually wrong to sentence kids to life in prison without parole, except for really bad crimes.

The Court needs to decide if it's ever okay to sentence kids to life in prison without parole. The answer is no.

The Court knows that kids' brains aren't fully grown until they're in their mid-twenties. So, it's impossible to know if a kid's bad behavior is just a phase or if they will always be bad. It's like guessing what the weather will be next month. You can't really be sure. And there’s no way to know if a kid will ever change their ways.

Since it's so hard to tell what a kid will be like in the future, some courts say that it's always wrong to sentence a kid to life in prison without parole. Other courts have different rules, and it's confusing. The Supreme Court needs to make a clear rule so that all kids are treated fairly.