Brief of Amici Curiae Charles Selby in Support of Defendant-appellant John Poole
Charles Selby
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Summary

Mandatory imposition of LWOP for those age 18 and above is unconstitutional for the same reasons the Miller Court barred such sentences for youth under age 18.

2021

Brief of Amici Curiae Charles Selby in Support of Defendant-appellant John Poole

Keywords Miller; mandatory LWOP; emerging adult; 18-year-old; brain development; adolescent development; Eighth Amendment (U.S.); diminished cognitive capacity; peer pressure; risky behavior; age of majority; Miller factors; de facto life sentence; underdeveloped character
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Summary of Argument

Much of what judicial history on this Issue relates ... chills, shames, and disgusts us. This aversion  caused the guardians or our national conscience to strike down Laws that permit the execution of  children under age 16. Seventeen years later, the logic of Thompson was extended to those under 18. A few years following, the Eighth Amendment categorically "prohibited the imposition  of a life sentence on a juvenile offender who did not commit homicide," These holdings of course  then led to "the Eighth Amendment forbid[ingl a sentencing scheme that mandates life in prison  without the possibility of parole for juvenile offenders.   

Accordingly, since children and adolescents have reduced cognitive, interpersonaL and  emotional capabilities, they are less blameworthy than mature adults when they engaged in  criminal behavior. And therefore It was only logical for the Court to decree teenage homicide offenders  permission to mitigate penalties for their offenses.  

The focal point here is that Dr. Steinberg and his renowned colleagues are the very medical  experts in whom the foundation of the above Miller trilogy lays. Therefore, for purposes of the Eighth  Amendment, states must defer to the "medical community's current standards that reflect improved  understanding over time"; they cannot "deviate from prevailing clinical standards," nor should this  Court continue such a course. In fact, the Sixth Circuit Court of Appeals recently demonstrated a willingness to meaningfully approach this issue with the sincerity of judicial truth seeking, alter  many years of outright denying medical science to aver “[f]or purposes of the Eighth  Amendment, an individual's birthday marks that bright [distinguishing between juvenile and adult. We decline to create exceptions- even for offenders with rare physiological conditions."

The Sixth Circuit's new stance came from Sherrill, where the Court fairly reasoned that while is has historically declined to extend Miller's reasoning to those over age 18, it must now look beyond historical conceptions to the evolving standards of decency that mark the progression of a maturing society - noting that members of its court have already begun to consider whether the line separating childhood and adulthood has shifted, pointing to various contexts in which it considers twenty-one the age of majority, as well as scientific and social research indicating that those under twenty-one retain the defining characteristic of youth.

Similarly, it is well past time for Michigan to dovetail the law with the medical science and empirical evidence that unequivocally supports the extension of Miller to those whom qualify from ages 18 to 25.  

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Summary of Argument

Historical Context

Judicial history has recognized the diminished culpability of juvenile offenders due to their underdeveloped cognitive, interpersonal, and emotional capacities. This understanding led to the prohibition of capital punishment for individuals under 16 (Thompson) and later under 18 (Roper). Subsequently, the Eighth Amendment barred life sentences without parole for juvenile non-homicide offenders (Graham) and for all juvenile offenders (Miller).

Cognitive and Developmental Considerations

These rulings were based on the recognition that adolescents possess reduced cognitive abilities, making them less blameworthy than adults. Medical experts, including Dr. Steinberg and his colleagues, provided the scientific foundation for this understanding.

Duty of States to Defer to Medical Standards

The Eighth Amendment requires states to adhere to prevailing medical standards regarding adolescent development. Deviation from these standards is impermissible.

Recent Judicial Recognition of Evolving Standards

The Sixth Circuit Court of Appeals in Sherrill acknowledged the need to consider evolving societal norms and scientific evidence. The court declined to create exceptions for individuals over 18, recognizing that the age of majority in various contexts has shifted to 21.

Extension of Miller to Young Adults

Based on the same scientific and empirical evidence that supported the Miller trilogy, it is argued that the protections afforded to juvenile offenders should be extended to individuals aged 18 to 25. This extension would align the law with the medical understanding of adolescent development and the evolving standards of decency in a maturing society.

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Summary of Argument

Historical Precedent

The courts have historically recognized that children and adolescents are less blameworthy than adults due to their underdeveloped cognitive and emotional abilities. This understanding led to laws prohibiting the execution of children under 16 and later under 18. It also resulted in a ban on life sentences without parole for juvenile offenders who did not commit homicide.

Medical Evidence

Medical experts, such as Dr. Steinberg, have provided scientific evidence supporting the idea that young adults up to age 25 still have developing brains and reduced culpability. This evidence played a crucial role in the Supreme Court's decision to extend Eighth Amendment protections to teenage homicide offenders.

Sixth Circuit's Shift

Recently, the Sixth Circuit Court of Appeals acknowledged the evolving medical understanding and declined to create exceptions for offenders over 18 with rare physiological conditions. The court recognized that the line between childhood and adulthood is shifting and that scientific and social research supports extending protections to those under 21.

Conclusion

It is time for Michigan to align its laws with the medical and empirical evidence that supports extending Eighth Amendment protections to young adults up to age 25. By doing so, the state would recognize the unique developmental characteristics of this age group and ensure that justice is tempered with an understanding of their reduced culpability.

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Summary of Argument

The Law Used to Be Unfair

In the past, kids and teenagers who committed crimes could be punished very harshly. They could even be executed or sentenced to life in prison without the chance of getting out.

Things Have Changed

Over time, people realized that this was unfair. Kids and teenagers are still developing and don't have the same understanding of right and wrong as adults. They also have a better chance of changing their behavior and becoming good citizens.

The Supreme Court Made a Rule

The Supreme Court, which is the highest court in the United States, ruled that it's against the Constitution to sentence kids and teenagers to life in prison without the possibility of parole for crimes other than murder.

Why This Matters

Scientists have shown that the brains of kids and teenagers are still developing. This means that they're less responsible for their actions than adults.

A New Idea

Some people believe that the Supreme Court's rule should also apply to young adults up to age 25. They argue that the science shows that young adults' brains are still developing too.

Michigan Should Change Its Laws

Michigan is one of the states that hasn't changed its laws yet. It's time for Michigan to catch up with the science and give young people a second chance.

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Summary of Argument

Why Kids and Teens Are Different

Kids and teenagers are not as grown-up as adults. Their brains are still growing, and they don't always think things through as well. They also don't always understand the consequences of their actions.

Court Decisions

Because of these differences, the courts have made some special rules for kids and teenagers. For example, kids under 16 can't be executed. And kids under 18 can't be sentenced to life in prison without the chance of getting out.

New Research

Now, scientists have learned even more about how kids and teenagers are different from adults. They've found that even young adults, up to age 25, still have some of the same brain differences as kids.

What This Means for Michigan

Some courts are starting to realize that young adults should also be treated differently in court. Michigan should do the same. The science shows that young adults deserve a chance to show that they can change and become responsible members of society.

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Footnotes and Citation

Cite

Brief of Amici Curiae Charles Selby in Support of Defendant-Appellant John Poole, People v. Poole, No. 161529 (Mich. 2021).

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