In Miller v. Alabama, the United States Supreme Court ruled that mandatory life without parole sentences are unconstitutional for youth who were under 18 at the time of their offenses under the Eighth Amendment’s prohibition on cruel and unusual punishment. 567 US 460, 465 (2012). The Court, relying on the same underlying scientific research used to bar the death penalty for youth, held that children are less culpable than their adult counterparts because of their immaturity, impetuosity, susceptibility to peer influence, and greater capacity for change. Id. at 465, 470–72. Further research now indicates that young people retain these characteristics beyond age 18. Because these emerging adults possess the same adolescent characteristics that the Supreme Court has determined reduce criminal culpability, mandatory life without parole sentences for this population are also disproportionate under the proportionality clause of the Illinois Constitution. Indeed, in recognition of the current developmental research, jurisdictions around the country are increasingly raising the age of adulthood above age 18 in situations that implicate the developmental characteristics relied upon in Miller. This trend challenges antiquated sentencing practices that wrongly turn on the arbitrary boundary of age 18. Further, as courts around the country have considered age and its attendant characteristics in sentencing even older adolescents, they have consistently found them less deserving of the harshest available penalties. Culpability is further diminished for individuals such as Antonio House who were convicted based on an accountability theory of liability and had minimal participation in the offense. Based on these considerations, this Court should affirm the Appellate Court’s judgement that Antonio’s mandatory life sentence was unconstitutional and remand his case for a new sentencing hearing.

Summary

Introduction

In Miller v. Alabama (2012), the Supreme Court of the United States held that mandatory life without parole sentences for juveniles (individuals under 18) violate the Eighth Amendment's prohibition against cruel and unusual punishment. The Court's decision was based on scientific evidence demonstrating that juveniles possess diminished culpability due to their developmental immaturity, impulsivity, vulnerability to peer pressure, and potential for rehabilitation.

Extension of Miller Principles to Emerging Adults

Recent research suggests that the developmental characteristics that mitigate culpability in juveniles extend beyond the age of 18. Emerging adults (individuals aged 18-25) exhibit similar traits, including reduced impulse control, susceptibility to peer influence, and a greater capacity for change.

National Trend Towards Raising the Age of Adulthood

In recognition of this research, jurisdictions across the country are raising the age of adulthood in contexts where developmental characteristics are relevant. This trend reflects an understanding that the arbitrary age of 18 does not accurately capture the developmental stage at which individuals attain full criminal culpability.

Diminished Culpability for Emerging Adults in Sentencing

Courts have consistently recognized the diminished culpability of emerging adults, even those older than 18, when imposing sentences. This is particularly true for individuals convicted under theories of accomplice liability or who played a minimal role in the offense.

Conclusion

Based on the principles established in Miller and the emerging scientific consensus, mandatory life without parole sentences for emerging adults are disproportionate and unconstitutional. Courts should consider the developmental characteristics of these individuals and provide them with the opportunity for a meaningful sentencing hearing that takes into account their reduced culpability and potential for rehabilitation.

Summary

Background:

In the landmark case of Miller v. Alabama (2012), the Supreme Court ruled that it is unconstitutional to sentence juveniles (under 18) to life in prison without the possibility of parole. The Court based its decision on scientific evidence showing that juveniles are less mature, impulsive, and susceptible to peer pressure than adults, making them less culpable for their crimes.

Emerging Research and the Age of Adulthood:

Recent research suggests that these same characteristics of adolescence extend beyond the age of 18. Young adults, known as "emerging adults," still exhibit immaturity, impulsivity, and a greater capacity for change. This has led many jurisdictions to raise the age of adulthood in situations where these developmental factors are relevant.

Sentencing for Emerging Adults:

As courts have considered the developmental characteristics of emerging adults, they have consistently found them less deserving of harsh penalties. This is especially true for individuals like Antonio House, who were convicted under a theory of "accountability," meaning they had minimal involvement in the crime.

Conclusion:

Based on the scientific evidence and the trend towards recognizing the unique characteristics of emerging adults, it is argued that mandatory life without parole sentences for this population are also unconstitutional. Antonio House's case should be remanded for a new sentencing hearing that takes into account his age and the mitigating factors involved.

Summary

What the Supreme Court Said

In a big decision, the Supreme Court said that kids under 18 who commit crimes can't automatically get life in prison without the chance of getting out. Why? Because kids are different from adults:

• They're not as mature.

• They make impulsive decisions.

• They're easily influenced by friends.

• They can change and grow.

New Research Shows Older Teens Are Still Developing

Now, scientists have found that these same traits apply to young people over 18 too. They're still developing and maturing, just like younger teens.

Other States Are Changing Their Laws

Because of this new research, many states are raising the age of adulthood for certain things, like sentencing for crimes. They recognize that young people deserve a second chance.

Antonio's Case

Antonio was convicted of a crime when he was over 18, but he didn't play a big role in it. Because of his age and the fact that he wasn't the main person involved, he shouldn't have gotten the harshest punishment possible.

Conclusion

It's time to change the way we sentence young people. They deserve a chance to learn from their mistakes and become productive members of society. Antonio's case should be sent back for a new sentencing hearing where his age and circumstances are taken into account.

Kids Shouldn't Get Life in Prison

Sometimes, kids do bad things. But the Supreme Court says that kids who are under 18 shouldn't get life in prison without the chance to get out. That's because kids are different from adults.

• They're not as mature.

• They make decisions without thinking.

• They're more likely to be influenced by their friends.

• They can change and become better people.

Now, scientists have learned that young people are still like kids in these ways even after they turn 18. So, some states are saying that people should be older than 18 to get life in prison without parole.

There's a man named Antonio House who was sentenced to life in prison when he was younger. He didn't do the crime himself, but he was there when it happened. The court says that his sentence is unfair because he's still young and didn't have a big part in the crime. They want him to have a chance to get a new sentence that's not so harsh.