Brief of Amici Curiae Juvenile Law Center, Campaign for Fair Sentencing of Youth, et al. in Support of Respondent Lee Boyd Malvo
Juvenile Law Center
Campaign for Fair Sentencing of Youth
SimpleOriginal

Summary

A life without parole sentence imposed without consideration of youth and its attendant characteristics is unconstitutional. Court decisions and legislation since Miller and Montgomery demonstrate widespread reliance on Miller.

2020 | Federal Juristiction

Brief of Amici Curiae Juvenile Law Center, Campaign for Fair Sentencing of Youth, et al. in Support of Respondent Lee Boyd Malvo

Keywords attendant characteristics of youth; developmentally appropriate; Miller; Montgomery; LWOP; life without parole; Eighth Amendment (U.S.); transient immaturity; temporary immaturity; retroactive relief; resentencing; mandatory sentencing; discretionary sentencing
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Summary of Argument

In Miller v. Alabama, this Court held that the mandatory imposition of life without parole sentences on juvenile offenders convicted of murder is cruel and unusual punishment. Miller v. Alabama, 567 U.S. 460, 489, (2012). Miller held that a category of punishment (life without parole sentences) cannot be imposed on a category of defendants (juvenile offenders) absent a consideration of chronological age and its hallmark features—among them, immaturity, impetuosity, and failure to appreciate risks and consequences. It prevents taking into account the family and home environment that surrounds him—and from which he cannot usually extricate himself—no matter how brutal or dysfunctional. It neglects the circumstances of the homicide offense, including the extent of his participation in the conduct and the way familial and peer pressures may have affected him. Indeed, it ignores that he might have been charged and convicted of a lesser offense if not for incompetencies associated with youth.

Miller, 567 U.S. at 477. Any life without parole sentence imposed without such consideration flouts this Court’s ruling. Courts and legislatures across the country have relied on this Court’s decision in Miller and found life without parole sentences for youth— whether imposed under a mandatory or discretionary sentencing scheme—invalid when imposed without consideration of the factors set forth in Miller.

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Summary of Argument

Sentencing Juvenile Offenders: The Impact of Miller v. Alabama

In the landmark case of Miller v. Alabama (2012), the Supreme Court ruled that mandatory life without parole (LWOP) sentences for juvenile offenders convicted of homicide violate the Eighth Amendment's prohibition against cruel and unusual punishment.

The Miller decision recognized that juvenile offenders possess distinct developmental characteristics, including immaturity, impulsivity, and a diminished capacity to fully comprehend the consequences of their actions. These factors must be considered in sentencing to ensure that the punishment is proportionate to the culpability of the offender.

Subsequent to Miller, courts and legislatures have consistently held that LWOP sentences for juvenile offenders are unconstitutional if imposed without individualized consideration of the mitigating factors outlined in the Supreme Court's ruling. This principle applies regardless of whether the sentencing scheme is mandatory or discretionary in nature.

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Summary of Argument

In the landmark case of Miller v. Alabama, the Supreme Court ruled that it is unconstitutional to automatically sentence juvenile offenders to life in prison without parole for murder.

Miller's Key Points:

  • Sentencing juvenile offenders to life without parole without considering their age and individual circumstances is cruel and unusual punishment.

  • Juvenile offenders have unique characteristics, such as immaturity and impulsivity, that make them less culpable than adults.

  • The court must consider the juvenile's family background, peer pressure, and the circumstances of the crime before imposing such a severe sentence.

Impact of Miller:

Following Miller, courts and legislatures nationwide have recognized that life without parole sentences for juveniles are inappropriate unless the factors outlined in Miller are carefully considered. This means that judges and lawmakers must take into account the youth's age, maturity level, and the specific circumstances of their case before imposing such a harsh punishment.

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Summary of Argument

In the case of Miller v. Alabama, the Supreme Court ruled that it's cruel and unusual to automatically sentence kids who commit murder to life in prison without parole.

The Court said that you can't just lump all kids together and give them the same punishment. You have to think about their age and what makes kids different from adults, like:

  • Immaturity: Kids aren't as developed as adults and may not fully understand the consequences of their actions.

  • Impulsivity: They might act without thinking things through.

  • Peer pressure: Kids can be easily influenced by their friends or family.

The Court also said that you have to consider the kid's home life and the circumstances of the crime. For example, if the kid was abused or neglected, or if they were pressured into committing the crime, that should be taken into account.

Since the Miller decision, courts and lawmakers around the country have ruled that it's not okay to sentence kids to life without parole without considering these factors.

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Summary of Argument

In a big court case, called Miller v. Alabama, the judges decided that it's not fair to automatically give kids who commit murder life in jail without parole.

The judges said that kids are different from adults because they're not as mature, they make bad decisions without thinking, and they don't understand the consequences of their actions. They also said that it's important to look at the kid's family life and how their friends and family might have influenced them.

So, if a kid gets sentenced to life in jail without parole, the court has to think about all of these things first. If they don't, it's not fair.

Other courts and states have agreed with this decision and have said that it's not right to give kids life in jail without parole without considering these things.

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Footnotes and Citation

Cite

Brief of Amici Curiae Juvenile Law Center, Campaign for Fair Sentencing of Youth, et al. in Support of Respondent Lee Boyd Malvo, Mathena v. Malvo, No. 18-217 (U.S. 2019).

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