Summary of Argument

Miller v. Alabama and Montgomery v. Louisiana mandate a presumption against life without parole for crimes committed while under the age of 18, because all children are capable of growth and rehabilitation. Amici submit this brief in support of Qu’eed Batts to share the stories of formerly incarcerated youth who have been released from prison and are now productive citizens in their communities. These real-life examples demonstrate the unique rehabilitative potential of youthful offenders who embody the Supreme Court of the United States’ pronouncement that “children are constitutionally different from adults for purposes of sentencing” because of their “diminished culpability and greater prospects for reform.” Miller v. Alabama, 132 S. Ct. 2455, 2464 (2012).

Like Qu’eed Batts and petitioners in related cases, the people whose stories are told in this brief were convicted of homicide crimes as children. Edwin Desamour, Sean Taylor, Xavier McElrath-Bey, and Joseph Farias could have spent their entire lives in prison. Instead, they matured, bettered themselves, and are now contributing members of their communities. Their stories of reform and redemption are not exceptions. There are juvenile "lifers" in Pennsylvania and around the country just like these men, including Qu’eed Batts, who were incarcerated at a young age and who are capable of rehabilitation—no matter how immature, troubled, or violent they may once have been. They are living proof that “children who commit even heinous crimes are capable of change.” Montgomery v. Louisiana, 136 S. Ct. 718, 736 (2016).

Summary of Argument

In the landmark cases of Miller v. Alabama and Montgomery v. Louisiana, the Supreme Court recognized the inherent rehabilitative potential of juvenile offenders, mandating a presumption against life without parole sentences for crimes committed under the age of 18. This brief presents real-life narratives of formerly incarcerated youth who, upon release, have become valuable members of society. These accounts serve as compelling evidence supporting the Court's assertion that "children are constitutionally different from adults for purposes of sentencing" due to their "diminished culpability and greater prospects for reform."

The stories of Edwin Desamour, Sean Taylor, Xavier McElrath-Bey, and Joseph Farias, all convicted of homicide as juveniles, demonstrate the transformative power of rehabilitation. Despite the possibility of life imprisonment, these individuals matured, pursued self-improvement, and are now making positive contributions to their communities. Their experiences are not isolated incidents but rather reflect the inherent capacity for change that exists within juvenile offenders, including Qu’eed Batts and others similarly situated.

These narratives provide irrefutable evidence that "children who commit even heinous crimes are capable of change." They underscore the importance of recognizing the unique rehabilitative potential of youthful offenders and the need to provide them with opportunities for redemption and reintegration into society. The cases of Miller v. Alabama and Montgomery v. Louisiana serve as a reminder that even those who have committed serious offenses as juveniles deserve a chance to prove their capacity for growth and contribute positively to their communities.

Summary of Argument

In the cases of Miller v. Alabama and Montgomery v. Louisiana, the Supreme Court ruled that juvenile offenders should not automatically receive life sentences without the possibility of parole. This decision was based on the recognition that children are different from adults in terms of their culpability and potential for rehabilitation.

This brief highlights the stories of several formerly incarcerated individuals who committed homicide crimes as juveniles:

• Edwin Desamour

• Sean Taylor

• Xavier McElrath-Bey

• Joseph Farias

These individuals were given the opportunity to mature and improve themselves, and they are now valuable members of society. Their stories demonstrate that even juvenile offenders who have committed serious crimes have the capacity for change and redemption.

These examples support the argument that juvenile offenders, such as Qu’eed Batts, should not be sentenced to life without parole. They have the potential to rehabilitate and become productive citizens, just like the individuals whose stories are shared in this brief.

Summary of Argument

The law says that kids who commit crimes should not automatically get life in prison without the chance for parole (getting out early). This is because kids are still growing and can change for the better.

This brief tells the stories of four people who were sent to prison for murder when they were kids:

• Edwin Desamour

• Sean Taylor

• Xavier McElrath-Bey

• Joseph Farias

These people could have spent their whole lives behind bars. But instead, they grew up, improved themselves, and are now helping their communities.

Their stories show that even kids who do terrible things can change. They prove that kids who are sent to prison for life can still be rehabilitated (helped to become better people). No matter how bad they were when they were young, they can still turn their lives around.

Summary of Argument

Some kids who do very bad things, like hurting someone, are given a punishment called "life in prison." This means they have to stay in jail for their whole lives. But there are people who believe that kids should not get this punishment because they are still young and can change.

There are stories of kids who were given life in prison but were later released. They grew up, learned from their mistakes, and became good people.

• Edwin Desamour

• Sean Taylor

• Xavier McElrath-Bey

• Joseph Farias

These people show that even kids who have done bad things can change and become helpful members of society. They prove that kids are different from adults and should have a chance to turn their lives around.