Summary of Argument

In the sentencing context, the Eighth Amendment requires courts to take into account that brain development is different in children and that juvenile offenders have a capacity to reform and grow. Those insights, which this Court has emphasized in numerous decisions—and which have been further confirmed by recent scientific research—are recognized by a wide range of judges, prosecutors, law enforcement officers, juvenile justice officials, correctional officers, and probation officers, many of whom have witnessed firsthand the potential for juvenile offenders to be rehabilitated. Amici respectfully urge the Court to ensure that this important principle is respected and enforced.

As officers of the law, amici also respectfully submit that the rule of law requires that this Court’s decisions recognizing constitutional protections not be subordinated to formalistic distinctions that undermine the Court’s reasoning. Petitioner’ssentence—in which he will not have the opportunity to be considered for release until he is 112 years old—was imposed to ensure that he will die in prison with no meaningful opportunity for release, even though he committed a non-homicide offense when he was a juvenile. To permit such a sentence merely because the sentence technically is for a term of years rather than “life in prison”—or because it is an aggregate sentence for more than one charge—would elevate form over substance and eviscerate this Court’s decision in Graham v. Florida, 560 U.S. 48 (2010). Prosecutors’ broad discretion to decide which charges to bring and how to structure them provides important flexibility that allows prosecutors to individualize charging decisions in the interest of justice. But the structuring of those charges should not affect the extent of the Eighth Amendment’s protections regarding the sentence imposed by the judge, or the applicability of this Court’s Eighth Amendment precedents.

Summary of Argument

The Eighth Amendment mandates that courts consider the developmental disparities between adults and juveniles, acknowledging the unique potential for rehabilitation among youthful offenders. This principle, repeatedly affirmed by the Court and corroborated by recent scientific research, enjoys broad support from legal professionals, including judges, prosecutors, law enforcement officers, juvenile justice officials, correctional officers, and probation officers, who have witnessed firsthand the capacity for reform in young offenders. The amici advocate for the Court to steadfastly uphold this crucial principle.

Furthermore, the amici assert that legal coherence necessitates a consistent application of constitutional protections, resisting formalistic distinctions that undermine established precedent. The petitioner's sentence, which effectively guarantees his death in prison without meaningful release despite a non-homicidal offense committed during his youth, undermines the Court's decision in Graham v. Florida. Such a sentence, imposed merely because it is a term of years rather than "life in prison" or because it is an aggregate sentence for multiple charges, elevates procedural formality over substantive constitutional protections. While prosecutors' discretionary charging decisions provide flexibility for individualized justice, these decisions should not undermine the Eighth Amendment protections applied by the judge, nor the Court's established Eighth Amendment precedents.

Summary of Argument

The Eighth Amendment mandates that courts consider the distinct developmental trajectory of the juvenile brain and the inherent capacity for reform in juvenile offenders when imposing sentences. This principle, repeatedly emphasized by the Supreme Court and supported by recent scientific research, is widely accepted by various legal professionals who have observed the rehabilitative potential of youthful offenders.

The Court's decisions recognizing these constitutional protections should not be undermined by technical distinctions that disregard their core principles. Sentences that effectively deny any possibility of release, even for non-homicide offenses committed by juveniles, contradict the spirit of Graham v. Florida. While prosecutors have discretion in charging decisions, the structure of those charges should not circumvent the Eighth Amendment's protections regarding sentencing or the applicability of the Court's precedents.

Summary of Argument

The Eighth Amendment of the US Constitution says that courts should consider how young people's brains develop differently and how they are capable of changing and improving. This Court has mentioned these ideas in many cases and scientists have backed them up with new research. Many people who work in the justice system, like judges, police officers, and probation officers, have seen how young offenders can change their lives. These groups are asking the Court to keep this important idea in mind when making decisions.

They also argue that the Court's decisions about Constitutional rights should be followed even when dealing with technical differences in how laws are written. The sentence given to the person who is asking for the Court's help is very harsh. He will never be considered for release until he is 112 years old, even though he did not commit murder as a young person. This sentence was given to make sure he dies in prison, even though the crime he committed doesn't usually have such a strict punishment. This sentence shouldn't be allowed just because it's written as a long term of years instead of "life in prison." It's important to look at what the sentence actually means, not just how it's worded. Prosecutors have a lot of power to choose which crimes to charge people with and how they structure those charges. But the way they choose to charge someone shouldn't decide how much protection the Eighth Amendment offers or whether the Court's past decisions about the Eighth Amendment apply.

Summary of Argument

The Eighth Amendment says that courts should think about how kids' brains are still growing and that young people can change and become better. Lots of people who work in the justice system, like judges, police officers, and probation officers, see this happen all the time. They agree that young people can change. So, this court should make sure that this important rule is always followed.

The law also says that the court's decisions about people's rights should be clear and fair. In this case, the person was given a sentence that means he won't be able to be released until he is really old. He did something wrong, but he didn't kill anyone. That sentence is like saying he has to stay in jail forever. This isn't right because the court has already said that people can't be sentenced to life in prison without a chance to get out, even if they did something bad when they were young.

So, just because the sentence is for a long time, instead of "life in prison," doesn't mean the rules about being fair to young people don't apply. The court should make sure that the rules are always followed, no matter how the sentence is written.