Brief of Amici Curiae Juvenile Law Center, Campaign for Fair Sentencing of Youth, et al. in Support of Respondent Lee Boyd Malvo
Marsha L. Levick
Riya Saha Shah
Heather Renwick
Rebecca Turner
SummaryOriginal

Summary

Life without parole sentences for youth are invalid when imposed without consideration of the factors set forth in Miller.

2011 | State Juristiction

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

Keywords Miller; LWOP; life without parole; attendant characteristics of youth; disproportionate sentences; Miller factors
Screenshot 2024-07-10 at 4.41.34 PM

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 appreciaterisks 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.

Open Amicus Brief as PDF

Summary of Argument

In Miller v. Alabama (2012), the Supreme Court ruled that mandatory life without parole sentences for juvenile offenders convicted of murder violate the Eighth Amendment's prohibition against cruel and unusual punishment. The Court's decision in Miller established that the following factors must be considered before imposing such a sentence:

  • Chronological age and its associated characteristics:

    • Immaturity

    • Impulsivity

    • Inability to fully appreciate risks and consequences

  • Family and home environment:

    • Potential for abuse or dysfunction

    • Limited ability to escape negative influences

  • Circumstances of the offense:

    • Level of participation

    • Influence of peer or familial pressure

  • Potential for lesser charges due to youthful incompetence:

The Court held that neglecting these factors in sentencing violates the principles established in Miller. Subsequent court rulings and legislative actions have recognized the importance of considering these factors in sentencing juvenile offenders, regardless of whether the sentence is mandatory or discretionary.

Open Amicus Brief as PDF

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 the possibility of parole for murder convictions.

Key Principles of Miller v. Alabama

The Court in Miller held that before sentencing a juvenile offender to life without parole, courts must consider the following factors:

  • Age: Juveniles are typically less mature, impulsive, and capable of understanding the consequences of their actions.

  • Family and Home Environment: The environment in which a juvenile grows up can have a significant impact on their behavior.

  • Circumstances of the Crime: The extent of the juvenile's involvement in the crime and any mitigating factors, such as peer pressure, should be taken into account.

  • Potential for Rehabilitation: Juveniles have a greater capacity for change and rehabilitation than adults.

Impact of Miller v. Alabama

Following the Miller decision, courts and legislatures across the country have recognized that life without parole sentences for juveniles are inappropriate without considering these factors. Whether the sentence is mandatory or discretionary, it is considered unconstitutional if it does not take into account the principles outlined in Miller.

Open Amicus Brief as PDF

Summary of Argument

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

The Court said that before sentencing a kid to life without parole, judges and lawmakers must consider these things:

  • Age: Kids are immature, impulsive, and don't fully understand the consequences of their actions.

  • Family and Home Life: Kids can't always escape bad home situations, which can affect their behavior.

  • Circumstances of the Crime: How much the kid was involved and whether they were pressured by family or friends.

  • Youthful Incompetence: Kids might not have been charged with a lesser crime if they were older and more capable.

Any life sentence without considering these factors goes against the Supreme Court's ruling. Courts and lawmakers around the country have used this ruling to say that life sentences for kids, even if they're not automatic, are not allowed unless these factors are considered.

Open Amicus Brief as PDF

Summary of Argument

In a big case called Miller v. Alabama, the highest court in the country said that it's not fair to automatically give kids who are found guilty of murder life in jail without parole. Parole means getting out of jail early for good behavior.

The court said that before giving a kid life without parole, judges and juries need to think about these things:

  • How old the kid is: Kids are still growing and changing, and they don't always think things through like adults do.

  • What their family and friends are like: Sometimes kids live in bad situations that make them do things they shouldn't.

  • What happened when the crime was committed: Did the kid play a big part or a small part? Were they pressured by others?

  • Could they have been charged with a less serious crime if they were older: Kids sometimes make mistakes that adults wouldn't.

The court said that if these things aren't considered, it's not fair to give a kid life without parole. Other courts and states have agreed with this and have said that kids shouldn't get life without parole unless these things are thought about first.

Open Amicus Brief as PDF

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, Randall Mathena, Warden, v. Lee Boyd Malvo, No. 18-217 (U.S.).

    Highlights