Summary of Argument

Uncontested research in developmental psychology and neuroscience continues to validate and confirm the conclusion that youth are different and less culpable than adults for their

actions, Compared to adults, children are less able to restrain their impulses and exercise self- control; less capable of considering alternative courses of action and avoiding unduly risky behaviors; and simply less capable than adults of mature judgment and decision-making, especially in the social contexts in which criminal behavior is most likely to arise. It is these signature qualities of adolescence that reduce these young people's culpability and increase their capacity for change.

The research confirms what those working in corrections and on criminal justice issues have long observed and documented — that youth are still in the process of forming coherent identities, and adolescent crime often reflects the signature and transient qualities of youth itself, rather than an entrenched bad character. Roper v Simmons, 543 US 551, 570; 125 S Ct 1183 (2005). Although some youthful offenders may commit criminal acts as adults, it is more likely that those children will mature and grow out of the behavior and characteristics that contributed to their criminal actions, becoming capable of rejoining society as productive citizens.

These profound differences between a child and an adult undermine any possible penological justification for punishing a child with a sentence that "guarantees he will die in prison without any meaningful opportunity to obtain release." Graham v Florida, 560 US 48, 79; 130 S Ct 2011, 2033 (2010). Moreover, it remains essentially impossible "even for expert psychologists to differentiate between the juvenile offender whose crime reflects unfortunate yet transient immaturity, and the rare juvenile offender whose crime reflects irreparable corruption," rendering the sentence of life without parole for a child inconsistent with the goals of corrections. Miller v Alabama, 132 S Ct 2455, 2469 (2012) (quoting Roper, 543 US at 573). This is true even of youth offenders who have committed the most serious crimes.

Amicus curiae believes that condemning an immature, vulnerable, and not-yet-fully- formed adolescent to live every remaining day of his life in prison does not serve legitimate penological objectives and is a constitutionally disproportionate punishment. Amicus curiae, relying on the particular experience, knowledge, and expertise of its members, urge this Court to consider the fact that many of those individuals currently serving this sentence can objectively demonstrate maturation, growth, and rehabilitation. It serves no penological purpose to continue to imprison these youth until death. Amicus curiae urges that retroactive application of Miller is consistent with the purposes of our criminal justice system and penological objectives by allowing rehabilitated youth the opportunity for release.

Summary of Argument

Developmental psychology and neuroscience research consistently demonstrates that youth are inherently different from adults, making them less culpable for their actions. Adolescents lack the impulse control, decision-making abilities, and mature judgment that characterize adults, particularly in social contexts where criminal behavior often emerges. These developmental characteristics, while reducing culpability, also increase the potential for change within youth.

Corrections and criminal justice professionals have long observed that adolescent crime often reflects the transient qualities of youth, rather than entrenched character flaws. While some young offenders may continue to commit crimes as adults, most mature and outgrow their criminal behavior, becoming productive members of society.

The significant developmental differences between children and adults undermine any justification for imposing sentences that guarantee lifelong imprisonment without the possibility of release. Expert psychologists struggle to differentiate between youth whose crimes reflect transient immaturity and those who exhibit irreversible corruption, making life without parole an ineffective and constitutionally disproportionate punishment. This holds true even for youth who have committed the most serious crimes.

Condemning an adolescent to a life sentence fails to serve legitimate penological objectives. Many currently serving such sentences demonstrate significant maturation, growth, and rehabilitation. Retroactive application of Miller aligns with the goals of the criminal justice system and penological objectives by affording rehabilitated youth the opportunity for release.

Summary of Argument

The legal system should recognize the distinct differences between the brains and behaviors of youth and adults when considering punishments for criminal offenses. Research in developmental psychology and neuroscience highlights the limitations of youth in areas like impulse control, decision-making, and social understanding. These developmental differences contribute to a reduced level of culpability and an increased capacity for change in young offenders.

While some youth may continue criminal behavior into adulthood, a significant portion of juvenile offenders will mature out of their past behaviors and become productive members of society. Sentencing a juvenile to life without parole, essentially a "death sentence," contradicts the fundamental principles of rehabilitation and contradicts the goals of the criminal justice system. This type of punishment fails to consider the developmental potential of youth and ignores the possibility of their rehabilitation.

The amicus curiae argues that the sentence of life without parole for juveniles is disproportionate and does not serve legitimate penological objectives. The amicus curiae, drawing on their expertise and experience, emphasizes the potential for rehabilitation in youth offenders. They advocate for the retroactive application of the Miller decision, which acknowledges the unique characteristics of youth and allows for the possibility of release for rehabilitated individuals.

Summary of Argument

Research shows that young people are different from adults and less responsible for their actions. Adolescents have less impulse control, struggle with decision-making, and often act based on immature judgment. These qualities are typical of their stage of development, which makes them less culpable for their actions and more likely to change their behavior.

Many young offenders commit crimes that reflect their temporary immaturity rather than a fixed character flaw. They are still developing their identities and have the potential to grow out of their criminal tendencies. Research suggests that young people are more likely to mature and become productive citizens.

Giving a child a life sentence without parole goes against the goals of the criminal justice system. Even expert psychologists find it challenging to distinguish between a young offender who is simply immature and one who is truly corrupted. Condemning a young person to spend their entire life in prison serves no legitimate purpose and is a disproportionate punishment.

Many young people serving life sentences without parole have matured, changed, and become rehabilitated. It is counterproductive to keep them imprisoned until death. Applying the ruling in Miller retroactively would align with the purpose of the criminal justice system and provide rehabilitated youth with a chance for release.

Summary of Argument

Kids are different than adults, especially when it comes to making choices. Their brains are still growing, and they don't always think about the consequences of their actions. This is why a lot of people think it's wrong to give kids the same punishments as adults, especially for crimes they committed when they were younger.

Researchers have shown that kids are less good at controlling themselves and making good decisions than grown-ups. This is especially true when they're hanging out with other kids, which is when they're most likely to get into trouble.

Many kids who do bad things grow up and change their ways. They learn from their mistakes and become good citizens. It wouldn't be fair to lock these kids up forever, especially if they've already shown they've changed.

Some experts think it's wrong to keep kids in prison for the rest of their lives, no matter what they did. They believe that it doesn't help anyone and that these kids deserve a chance to get out and live a normal life.