Brief of Amici Curiae Children and Family Justice Center et al. in Support of Defendant-appellee
Shobha L. Mahadev
Lydette S. Assefa
SimpleOriginal

Summary

Emerging adults should not be subject to life without parole sentences under U.S. Supreme Court precedent and Illinois law because they possess the same developmental characteristics as adolescents.

2020 | State Juristiction

Brief of Amici Curiae Children and Family Justice Center et al. in Support of Defendant-appellee

Keywords brain; brain plasticity; behavior regulation; emerging adults; dopamine; mandatory LWOP; developmental characteristics; Roper; impulsivity; cold cognition; decision-making; hot cognition; risky behavior
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Summary of Argument

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 of Argument

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 in Cases of Accountability Theory

Courts have consistently recognized that individuals convicted under an accountability theory of liability, where their participation in the offense was minimal, have diminished culpability. This principle is particularly relevant in cases involving emerging adults, who may be more susceptible to peer pressure and less able to fully appreciate the consequences of their actions.

Conclusion

Based on the evolving scientific understanding of adolescent development and the national trend towards recognizing the diminished culpability of emerging adults, courts should extend the principles of Miller v. Alabama to this population. Mandatory life without parole sentences for emerging adults are disproportionate and violate the proportionality clause of the Illinois Constitution.

Summary of Argument

In 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 and responsible than adults

  • More impulsive and susceptible to peer pressure

  • More likely to change and rehabilitate

Emerging Research and the Age of Adulthood:

Recent research suggests that these same characteristics extend beyond age 18. Young adults, known as "emerging adults," still exhibit adolescent traits that reduce their criminal responsibility.

National Trend:

Many states are raising the age of adulthood in situations where these developmental characteristics are relevant. This reflects the growing recognition that the age of 18 is an arbitrary boundary for sentencing purposes.

Diminished Culpability:

Courts have consistently found that older adolescents (18+) are less deserving of severe penalties. This is especially true for individuals like Antonio House, who were convicted under a theory of "accountability" and had limited involvement in the crime.

Conclusion:

Based on the scientific evidence and legal precedent, the Appellate Court ruled that Antonio's life sentence was unconstitutional. The case should be sent back for a new sentencing hearing that takes into account his age and diminished culpability.

Summary of Argument

What the Supreme Court Said

In the case of Miller v. Alabama, the Supreme Court said that it's not fair to automatically sentence kids under 18 to life in prison without the chance of parole. Why? Because kids are different from adults:

  • They're not as mature.

  • They make impulsive decisions.

  • They're easily influenced by others.

  • They have a better chance of changing for the better.

New Research Shows Older Teens Are Still Developing

Now, scientists have found that these same differences apply to young people over 18 too. They're still developing and shouldn't be treated the same as adults when it comes to sentencing.

Other States and Courts Are Changing

Because of this new research, many places are raising the age of adulthood for certain situations, like sentencing. They recognize that it's not right to punish young people as harshly as adults, even if they're over 18.

Antonio's Case

Antonio House was sentenced to life without parole even though he didn't directly commit the crime. The court should reconsider his sentence because:

  • He's still young and has the potential to change.

  • He wasn't the main person involved in the crime.

It's time to update our sentencing laws to reflect the science that shows young people deserve a second chance.

Summary of Argument

In a very important case called Miller v. Alabama, the highest court in the United States said that it's not fair to give kids under 18 life in prison without the chance to get out. Why? Because kids are different from adults.

Kids are still growing and changing. They don't always think things through before they do them. They're also more likely to be influenced by their friends. And they have a better chance of becoming better people as they get older.

Now, scientists have learned that young people keep these same traits even after they turn 18. So, it's not fair to give them the same punishment as adults. Other places are starting to agree. They're saying that people should be older than 18 to be treated like adults in court.

There's a young man named Antonio House who was found guilty of a crime even though he didn't do much to help. Because of his age and because he didn't do much, he shouldn't have gotten life in prison without parole. The court should give him a new chance and let him have a different sentence.

Footnotes and Citation

Cite

Brief of Amici Curiae Children and Family Justice Center et al. in Support of Defendant-Appellee, People v. House, No. 125124 (Ill. Dec. 22, 2020).

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