Summary of Argument

The case of Ahmad Bright raises fundamental constitutional issues unresolved by this Court in Miller v. Alabama, 132 S. Ct. 2455 (2012). At issue is the constitutional injury suffered by juveniles under the Massachusetts sentencing scheme, a scheme common throughout the country. Massachusetts law provides no occasion for the court to consider the unique neurodevelopmental issues of a 16-year-old at the time of prosecution, conviction or sentencing for second degree murder. In Massachusetts, the charge of homicide, whatever its degree, requires a mandatory transfer to an adult court. Mass. Gen. Laws ch. 119 § 74 (2013). In the adult system, a conviction for second degree murder imposes a mandatory life sentence. After fifteen years, the juvenile may petition for review by the parole board, which has unfettered discretion to grant or deny parole. Therefore, the possibility of parole, although statutorily available, is not meaningful.

The constitutional injury to Bright is made worse here not merely because of the charge and conviction. The theory of homicide underlying Bright’s conviction is not one of direct participation in the murder but a derivative liability theory—here, joint venture. Derivative liability ignores the scientific findings underscored by this Court in Miller and its predecessors, Graham v. Florida, 560 U.S. 48 (2010) and Roper v. Simmons, 543 U.S. 551 (2005), and more recent scientific evidence showing that adolescent development is strongly context dependent: risk taking behavior, deficits in adolescent decision- making, and vulnerability to peer influence are exacerbated in certain settings. Theories of derivative liability, like joint venture, that preclude any individualized examination of the circumstances of the defendant’s participation run afoul of this Court’s holding in Miller and the Eighth Amendment proportionality requirements.

Summary of Argument

The case of Ahmad Bright highlights fundamental constitutional questions left unanswered by the Supreme Court's decision in Miller v. Alabama (2012). Specifically, it addresses the constitutional implications of sentencing juveniles under the Massachusetts scheme, which is prevalent in many jurisdictions across the United States.

Massachusetts Sentencing Scheme and Its Impact on Juveniles

Under Massachusetts law, juveniles charged with homicide are automatically transferred to adult court. A conviction for second-degree murder carries a mandatory life sentence. While parole is theoretically available after 15 years, the parole board possesses absolute discretion in granting or denying it, rendering the possibility of parole effectively meaningless.

This sentencing scheme fails to account for the distinct neurodevelopmental characteristics of juveniles, which have been recognized by the Supreme Court in Miller and its predecessors. These characteristics include heightened risk-taking behavior, impaired decision-making, and susceptibility to peer influence.

Derivative Liability and Its Constitutional Implications

Bright's conviction was based on a theory of derivative liability, namely joint venture. This theory disregards the individualized circumstances of the defendant's involvement, which is at odds with the Supreme Court's holding in Miller and the Eighth Amendment's proportionality requirement.

Derivative liability theories, such as joint venture, prevent courts from considering the context-dependent nature of adolescent development. They ignore the scientific evidence that demonstrates how certain settings can exacerbate the aforementioned neurodevelopmental characteristics of juveniles.

Conclusion

The case of Ahmad Bright underscores the need for courts to address the unresolved constitutional issues surrounding juvenile sentencing. The Massachusetts sentencing scheme, and similar schemes in other jurisdictions, fail to adequately consider the unique developmental factors of juveniles and the implications of derivative liability theories. This violates the Eighth Amendment's prohibition against cruel and unusual punishment.

Summary of Argument

Ahmad Bright's case highlights important constitutional questions that were not fully addressed in the Supreme Court's previous ruling in Miller v. Alabama. The issue is the harm caused to juveniles under Massachusetts' sentencing laws, which are similar to those in many other states.

Massachusetts Sentencing Laws for Juveniles

In Massachusetts, any juvenile charged with murder is automatically transferred to adult court. If convicted of second-degree murder, they face a mandatory life sentence. After 15 years, they can apply for parole, but the parole board has complete discretion to grant or deny it. This means that the possibility of parole is not guaranteed.

Constitutional Concerns

Bright's case raises concerns because it does not allow courts to consider the unique brain development of 16-year-olds when making sentencing decisions. Scientific evidence shows that adolescents are still developing their decision-making abilities, are more vulnerable to peer pressure, and are more likely to engage in risky behavior in certain situations.

Derivative Liability

Bright was convicted of murder based on a theory of "joint venture," which means he was held responsible for the actions of others involved in the crime. This type of liability does not take into account the individual circumstances of the defendant's participation. This conflicts with the Supreme Court's ruling in Miller, which requires courts to consider the individual characteristics of juvenile offenders before imposing harsh sentences.

In conclusion, Ahmad Bright's case highlights the need for courts to consider the unique developmental factors of juveniles when making sentencing decisions, even in cases where derivative liability is involved.

Summary of Argument

Ahmad Bright's case shows a problem with how young people are sentenced in Massachusetts and other states.

The Problem:

• When a 16-year-old is charged with murder in Massachusetts, they are automatically tried as an adult.

• If they are found guilty of second-degree murder, they must serve a life sentence.

• After 15 years, they can ask for parole, but it's not guaranteed.

Why This Is Unfair:

• Young people's brains are still developing, and they may not fully understand the consequences of their actions.

• They are also more likely to be influenced by their friends and surroundings.

• In Bright's case, he was charged with murder even though he didn't directly kill anyone. This is called "joint venture," and it doesn't take into account the individual's role in the crime.

• This type of sentencing goes against the idea that punishments should be fair and proportional to the crime.

Summary of Argument

Ahmad Bright is a young person who was sentenced to life in prison without the chance of parole. This raises important questions about how we treat young people who commit serious crimes.

How Young People Are Sentenced in Massachusetts

In Massachusetts, if a 16-year-old is charged with murder, they are automatically tried as an adult. If they are found guilty of second-degree murder, they must be sentenced to life in prison. After 15 years, they can ask for parole, but it is not guaranteed.

Why This Is Unfair

Scientists have shown that young people's brains are still developing. This means that they may not fully understand the consequences of their actions or be able to control their impulses. They are also more likely to be influenced by their friends.

Ahmad Bright was convicted of murder based on a theory called "joint venture." This means that he was held responsible for the actions of someone else. This theory does not take into account the fact that young people may not have been fully involved in the crime or may have been pressured into participating.

It is not fair to sentence young people to life in prison without considering their age and the circumstances of the crime.