Brief for the NAACP Legal Defense & Educational Fund, Inc., Charles Hamilton Houston Institute for Race & Justice, and National Association of Criminal Defense Lawyers as Amici Curiae in Support of Petitioners
John Payton
Debo P. Adegbile
Christina Swarns
Jin Hee Lee
SimpleOriginal

Summary

Youthful offenders under 18 shouldn't face life without parole sentences due to their distinct characteristics hindering effective legal representation. This jeopardizes fair sentencing, overlooking culpability and guilt.

2009 | Federal Juristiction

Brief for the NAACP Legal Defense & Educational Fund, Inc., Charles Hamilton Houston Institute for Race & Justice, and National Association of Criminal Defense Lawyers as Amici Curiae in Support of Petitioners

Keywords attorney-client relationship; JLWOP; juvenile life without parole; characteristics of youth; immaturity; decision-making; peer pressure; plea bargains
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Summary of Argument

Experience, science and this Court’s precedents all recognize that children are fundamentally different than adults. One of the most significant aspects of this difference is that children who commit criminal offenses are less culpable than adults. Roper v. Simmons, 543 US. 563, 569-70 (2005). These principles bear directly on the constitutionality of juvenile life without parole sentences. Such sentences fail to comport with the requirements of the Eighth Amendment for the reasons raised by the Petitioners and supporting amici and because the unique characteristics of youth can critically undermine defense counsel’s ability to effectively assist their teenaged clients, and the compromised attorney-client relationship contributes to an increased likelihood of unreliable sentencing outcomes that fail to reflect culpability and guilt. Atkins v. Virginia, 536 U.S. 304, 320 (2002). For these reasons, individuals younger than age 18 at the time of the offense should not be subject to life without parole sentences.

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Summary of Argument

Empirical evidence, scientific research, and legal precedent converge to establish the fundamental distinction between juveniles and adults in terms of culpability for criminal offenses. This distinction is particularly pertinent to the constitutionality of juvenile life without parole (LWOP) sentences under the Eighth Amendment.

Juvenile Culpability and Sentencing

In Roper v. Simmons (2005), the Supreme Court recognized that juveniles possess diminished culpability compared to adults due to their underdeveloped cognitive abilities, susceptibility to peer pressure, and limited life experience. These factors render LWOP sentences disproportionately harsh and fail to adequately account for the mitigating circumstances of youth.

Attorney-Client Relationship and Sentencing Outcomes

The unique characteristics of adolescence can also compromise the attorney-client relationship, which is essential for effective legal representation. Juveniles may struggle to communicate effectively with their attorneys, understand legal proceedings, and make informed decisions. This compromised relationship increases the likelihood of unreliable sentencing outcomes that fail to accurately reflect the juvenile's culpability and guilt.

Conclusion

In light of the diminished culpability of juveniles and the potential for compromised legal representation, the Eighth Amendment prohibits the imposition of LWOP sentences on individuals who were under the age of 18 at the time of the offense. Such sentences fail to recognize the fundamental differences between juveniles and adults and violate the constitutional guarantee against cruel and unusual punishment.

Summary of Argument

Research, legal precedent, and scientific evidence demonstrate that children are inherently different from adults, particularly in terms of their criminal culpability. This distinction is crucial in evaluating the constitutionality of life without parole (LWOP) sentences for juvenile offenders.

Diminished Culpability

Children possess a diminished capacity for decision-making and impulse control compared to adults. This reduced culpability makes LWOP sentences disproportionately harsh for juvenile offenders.

Compromised Attorney-Client Relationship

The unique characteristics of youth can hinder effective legal representation. Teenagers may struggle to understand legal proceedings and communicate effectively with their attorneys. This compromised relationship increases the risk of unreliable sentencing outcomes that fail to accurately reflect the offender's guilt and culpability.

Eighth Amendment Violation

LWOP sentences for juveniles violate the Eighth Amendment's prohibition against cruel and unusual punishment. Such sentences fail to consider the mitigating factors associated with youth, such as their diminished culpability and potential for rehabilitation.

Conclusion

Based on the evidence presented, it is unconstitutional to impose LWOP sentences on individuals who were under 18 at the time of the offense. These sentences disregard the fundamental differences between children and adults and fail to provide a fair and just punishment.

Summary of Argument

Science and experience tell us that kids who break the law are less responsible for their actions than adults.

Why?

Because kids' brains are still developing, they don't always understand the consequences of their actions. They're also more likely to act on impulse or peer pressure.

This matters in court.

Lawyers might not be able to help their teenage clients as effectively because of these differences. This can lead to unfair sentences that don't take into account how young the person was when they committed the crime.

Conclusion:

Teens who commit crimes should not be sentenced to life in prison without the possibility of parole. It's not fair and it doesn't make sense.

Summary of Argument

When kids do something wrong, they should be punished less than adults because they're not as responsible for their actions. Here's why:

  • Kids' brains are still growing. They don't always think things through or understand the consequences of their actions.

  • Kids are more likely to be influenced by others. They might do something bad because their friends are doing it.

  • Kids can change and grow. They're not the same as they will be when they're older.

Because of these differences, it's not fair to give kids the same punishments as adults, like life in prison without the chance to get out. It's also harder for lawyers to help kids in court, which can lead to unfair punishments.

Footnotes and Citation

Cite

NAACP Legal Defense & Educational Fund, Inc. et al., Brief of Amici Curiae in Support of Petitioners, Terrence Jamar Graham et al. v. State of Florida, Nos. 08-7412 & 08-7621 (U.S. Aug. 1, 2009)

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