Brief of Amici Curiae Juvenile Law Center, American Civil Liberties Union of Michigan, Juvenile Sentencing Project at Quinnipiac University School of Law, and Deborah Labelle in Support of Defendant-appellant John Antonio Poole
American Civil Liberties Union of Michigan
Juvenile Sentencing Project at Quinnipiac University School of Law
Deborah Labelle
Juvenile Law Center
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Summary

The scientific research used to bar the death penalty for juveniles should now bar mandatory LWOP sentences for young people above age 18 because research confirms young people retain these characteristics beyond age 18.

2022 | State Juristiction

Brief of Amici Curiae Juvenile Law Center, American Civil Liberties Union of Michigan, Juvenile Sentencing Project at Quinnipiac University School of Law, and Deborah Labelle in Support of Defendant-appellant John Antonio Poole

Keywords cognitive characteristics; impulsivity; greater capacity for change; peer pressure; mandatory LWOP; lesser culpability; lesser blameworthiness; neurodevelopmental growth; Miller; cruel and unusual punishment; disproportionate sentences; excessive punishment; Eighth Amendment (U.S.); age of adulthood; age 18; youth above age 18; peer pressure; vulnerability to peer pressure; young adults
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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 individuals who were under age 18 at the time of their offenses under the Eighth Amendment’s prohibition on cruel and unusual punishment. 567 US 460, 465; 132 S Ct 2455; 183 L Ed 2d 407 (2012). The Court, relying on the same underlying scientific research used to bar the death penalty for juveniles, 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 471-72. Further research now confirms that young people retain these characteristics beyond age 18. Because older adolescents retain the same cognitive characteristics that courts have determined render youth less culpable than adults, mandatory life without parole sentences for this population are also disproportionate under both the Eighth Amendment and Article 1, § 16, of Michigan’s 1963 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, reinforcing how current sentencing practices 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. Amici urge this Court to find that 18-year-olds, like John Antonio Poole, are developmentally indistinguishable from defendants under age 18 and therefore cannot constitutionally be sentenced to mandatory life without parole because such a sentence would be cruel or unusual under Article 1, § 16 of Michigan’s Constitution and would defy the rule set forth in Miller.

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Summary of Argument

In Miller v. Alabama (2012), the Supreme Court of the United States held that mandatory life without parole sentences for juveniles 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. Recent research suggests that these same cognitive characteristics persist beyond the age of 18, raising questions about the constitutionality of mandatory life without parole sentences for older adolescents.

Studies have shown that individuals aged 18 and older retain the same developmental traits that render juveniles less culpable than adults. These traits include:

  • Reduced impulse control

  • Increased susceptibility to peer influence

  • A greater capacity for rehabilitation

Jurisdictions across the country are recognizing the developmental immaturity of older adolescents and raising the age of adulthood in contexts where these characteristics are relevant. Courts have consistently found that older adolescents, even those above the age of 18, are less deserving of severe punishments due to their diminished culpability.

Based on the scientific evidence and evolving sentencing practices, it is argued that 18-year-olds are developmentally indistinguishable from juveniles and should therefore be protected from mandatory life without parole sentences. Such sentences would violate the Eighth Amendment's prohibition against cruel and unusual punishment and the principles established in Miller v. Alabama.

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Summary of Argument

In the landmark case of Miller v Alabama, 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 capable of change than adults.

Recent research has shown that young adults (18 and older) still have many of the same cognitive characteristics as juveniles. This means that they are also less culpable for their actions than adults. Despite this research, many states still allow 18-year-olds to be sentenced to mandatory life without parole. This is unfair and disproportionate, as it does not take into account their developmental immaturity.

Other jurisdictions are recognizing the importance of developmental research and are raising the age of adulthood in certain situations. This shows that the current practice of sentencing 18-year-olds to life without parole is outdated and arbitrary.

The evidence is clear that 18-year-olds are developmentally similar to juveniles and should not be subject to mandatory life without parole sentences. Such sentences are cruel and unusual and violate the constitutional rights of these young adults.

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Summary of Argument

In Miller v Alabama, the Supreme Court said that it's cruel and unusual punishment to automatically sentence teenagers to life in prison without the chance of parole. This is because teenagers are different from adults in important ways:

  • They're not as mature.

  • They make impulsive decisions.

  • They're easily influenced by others.

  • They have a better chance of changing and becoming better people.

Now, scientists have found that these same differences apply to teenagers who are 18 and older. This means that it's also cruel and unusual punishment to automatically sentence 18-year-olds to life without parole. Because of this new research, many states are changing their laws to treat older teenagers differently. They're also giving judges more options when sentencing teenagers, even those who are 18 or older.

The court should rule that 18-year-olds are like younger teenagers and shouldn't be automatically sentenced to life without parole. This would be a fair and just decision that follows the science and gives teenagers a chance to turn their lives around.

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Summary of Argument

The Supreme court in the United States said that kids under 18 should not be sentenced to life in prison without parole. The court said that kids are different from adults because:

  • They don't think as well before they act.

  • They are more likely to do what their friends tell them.

  • They can change and become better people.

Now, scientists have learned that young people over 18 are still a lot like kids in these ways. Because of what scientists have learned, many states are changing their laws to treat people over 18 more like kids when they get in trouble.

Some people believe that 18-year-olds should not be sentenced to life in prison without parole because it is too harsh. They think that these young people still have the chance to change and should not be locked away forever.

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Footnotes and Citation

Cite

Brief of Amici Curiae Juvenile Law Center, American Civil Liberties Union of Michigan, Juvenile Sentencing Project at Quinnipiac University School of Law, and Deborah LaBelle in Support of Defendant-Appellant John Antonio Poole, People v. Poole, No. 161529 (Mich. 2021).

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