Summary of Argument

This brief is submitted in support of the resentencing of Angel Alejandro. Amici respectfully urge the Court to reject the U.S. Sentencing Guidelines calculation as the starting point, and rather to follow the teachings of the U.S. Supreme Court by accounting for developments in juvenile justice, science, and criminology which were not considered by the Court at Mr. Alejandro's original sentencing. Mr. Alejandro's sentence should be reduced appropriately.

This Court agreed to resentence Mr. Alejandro in the wake of Miller v. Alabama, 132 S. Ct. 2455 (2012), in which the Supreme Court banned mandatory life without parole sentences for juveniles who commit crimes before the age of 18. In Miller, the Court predicted that such sentences would be uncommon and rarely imposed because juveniles bear "diminished culpability and greater prospects for reform." Id. at 2464.

In this brief, we argue that this Court may not use the Sentencing Guidelines to calculate Mr. Alejandro's sentence because the Guidelines, if applied, would yield an unconstitutional starting point: namely, a life sentence without possibility of parole. Miller requires the Court to take into account that a defendant who was a child at the time of the crime cannot be considered the same as an adult for the purpose of sentencing. This brief also argues that new scientific and criminological knowledge developed since Mr. Alejandro was first sentenced indicates that this Court should not re-impose a life sentence or its equivalent. For biological and penological reasons, downward adjustments in Mr. Alejandro's sentence are necessary to ensure that his punishment is proportionate to the reduced responsibility he bore as a child and reflective of his subsequent maturation and rehabilitation. We leave it to the Federal Defenders to argue the specific facts about Mr. Alejandro's conduct and characteristics at the time of the crime or thereafter that may further mitigate his culpability

Summary of Argument

This brief advocates for the resentencing of Angel Alejandro, urging the Court to deviate from the U.S. Sentencing Guidelines and instead prioritize the principles outlined in Miller v. Alabama. The brief contends that the Guidelines, if applied, would result in an unconstitutional starting point, a life sentence without parole, directly contradicting the Supreme Court's mandate in Miller to consider the diminished culpability and potential for rehabilitation inherent in juvenile offenders.

The brief argues that the Sentencing Guidelines are incompatible with the Miller decision and that the Court should not rely on them for calculating Mr. Alejandro's sentence. The brief further contends that recent advancements in scientific and criminological understanding necessitate a reevaluation of Mr. Alejandro's sentence. The brief suggests that biological and penological considerations necessitate a reduction in Mr. Alejandro's sentence to ensure a punishment proportionate to his diminished culpability as a juvenile and reflective of his subsequent maturation and rehabilitation.

Summary of Argument

This brief is submitted in support of resentencing Angel Alejandro. The authors urge the court to disregard the U.S. Sentencing Guidelines calculation as a starting point for resentencing. Instead, the authors argue that the court should adhere to Supreme Court precedent, accounting for developments in juvenile justice, science, and criminology that were not considered at Mr. Alejandro’s original sentencing.

The court agreed to resentence Mr. Alejandro following the Supreme Court’s ruling in Miller v. Alabama. The Court in Miller banned mandatory life without parole sentences for juveniles who commit crimes before the age of 18. The court in Miller anticipated that such sentences would rarely be imposed because juveniles bear “diminished culpability and greater prospects for reform."

This brief argues that the court cannot use the Sentencing Guidelines to calculate Mr. Alejandro's sentence because the Guidelines would produce an unconstitutional sentence – a life sentence without the possibility of parole. The brief argues that Miller requires the court to consider that a defendant who was a child at the time of the crime cannot be considered the same as an adult for the purpose of sentencing.

This brief also argues that new scientific and criminological knowledge has developed since Mr. Alejandro was first sentenced, indicating that the court should not re-impose a life sentence. For biological and penological reasons, downward adjustments in Mr. Alejandro's sentence are necessary to ensure that his punishment is proportional to the reduced responsibility he bore as a child, and is reflective of his subsequent maturation and rehabilitation.

Summary of Argument

This document argues that Angel Alejandro's sentence should be reduced. The document asks the court to consider recent changes in juvenile justice, science, and criminology that weren't available when Mr. Alejandro was first sentenced.

The court agreed to re-evaluate Mr. Alejandro's sentence after a Supreme Court case called Miller v. Alabama ruled that mandatory life sentences for juveniles were unconstitutional. The Supreme Court said that these sentences should be rare because young people are less responsible for their actions and have more potential for change than adults.

This document explains that the court should not use the Sentencing Guidelines to calculate Mr. Alejandro's sentence because using them would lead to an unreasonable sentence – a life sentence without parole. The document argues that the Sentencing Guidelines don't properly account for the differences between young people and adults when it comes to crime. It also argues that new scientific evidence and knowledge about how young people develop show that Mr. Alejandro's sentence should be reduced.

The document explains that Mr. Alejandro's sentence should be reduced to reflect his age at the time of the crime and the fact that he has matured and changed since then. It leaves it up to Mr. Alejandro's legal team to provide specific details about his case that support reducing his sentence.

Summary of Argument

Angel Alejandro is asking the court to reduce his sentence. The court is considering this request because of a Supreme Court case that said it's not fair to give someone who was a child when they committed a crime the same punishment as an adult.

This document argues that the court should not use the Sentencing Guidelines to decide Angel's sentence because those guidelines would lead to an unfair punishment. It also says that scientists and criminologists have learned new things since Angel was first sentenced, and these new things show that he doesn't deserve a life sentence.

The document explains that because Angel was a child when he committed the crime, he should be given a shorter sentence. It also says that Angel has grown up and changed since then and has been working to be a better person.