Brief of Amici Curiae Juvenile Law Center, Civitas ChildLaw Clinic, and Campaign for the Fair Sentencing of Youth in Support of Petitioner-Appellant James Walker
Bruce Boyer
Marsha Levick
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Summary

Miller recognizes that children are different from adults and deserve lesser punishments; it cautions against life without parole sentences for juveniles.

2015 | State Juristiction

Brief of Amici Curiae Juvenile Law Center, Civitas ChildLaw Clinic, and Campaign for the Fair Sentencing of Youth in Support of Petitioner-Appellant James Walker

Keywords Miller; children; juveniles; life without parole; LWOP; youth; mitigating factor; individualized sentencing hearing; homicide; diminished culpability; lesser blameworthiness; heightened capacity for rehabilitation
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Summary of Argument

U.S. Supreme Court precedent establishes that children are fundamentally different from adults and categorically less deserving of the harshest fonns of punishment. Most recently, in Miller v. Alabama, 132 S. Ct. 2455 (2012), the Supreme Court established a presumption against imposing life without parole sentences on juvenile homicide offenders. Miller further requires that, prior to imposing a life without parole sentence on a juvenile offender, the sentencer must examine factors that relate to the youth's diminished culpability and heightened capacity for rehabilitation. Though Miller involved a mandatory life without parole sentence, its holding that juvenile offenders facing juvenile life without parole are entitled to individualized sentencing hearings in which their age and related characteristics are considered applies in discretionary sentencing cases as well. Because Mr. Walker did not receive a sentencing bearing in which his age and related characteristics were considered, his sentence should be vacated. Moreover, this Court must provide guidance to ensure that juvenile life without parole sentences, if imposed at all, are not imposed in an arbitrary and capricious manner.

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Summary of Argument

The U.S. Supreme Court has consistently recognized the unique characteristics of juveniles, particularly in the context of sentencing. In Miller v. Alabama, the Court established a presumption against imposing life without parole sentences on juvenile homicide offenders, recognizing their diminished culpability and greater potential for rehabilitation. Miller further mandates individualized sentencing hearings to consider factors specific to the juvenile offender, including their age and other related characteristics. While Miller involved a mandatory life without parole sentence, its principle of individualized sentencing hearings applies to discretionary sentencing cases as well. Therefore, Mr. Walker's sentence should be vacated because he was not afforded a sentencing hearing that properly considered his age and related characteristics. This Court must provide clear guidelines to ensure that juvenile life without parole sentences, when imposed, are not applied arbitrarily or capriciously.

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Summary of Argument

The U.S. Supreme Court has established legal precedent that recognizes children as distinct from adults, with a significantly reduced culpability for serious crimes. This principle, most notably articulated in the case of Miller v. Alabama, prohibits the automatic imposition of life-without-parole sentences on juveniles convicted of homicide.

The Miller decision mandates that judges, prior to sentencing a juvenile to life without parole, must carefully consider factors relevant to the youth's diminished culpability and enhanced potential for rehabilitation. These factors, such as developmental immaturity, impulsivity, and susceptibility to peer influence, are crucial in determining the appropriate punishment.

While Miller specifically addressed mandatory life-without-parole sentences, its core principle extends to discretionary sentencing situations as well. This means that even when a judge has the discretion to impose a different sentence, they must still consider the juvenile's age and unique characteristics during the sentencing process.

In Mr. Walker's case, the absence of a sentencing hearing that adequately addressed his age and relevant traits suggests a violation of Miller's established legal framework. Consequently, his sentence should be vacated and a new sentencing hearing conducted.

Furthermore, this court has a responsibility to provide clear guidelines for imposing life-without-parole sentences on juveniles, ensuring that such sentences are not applied arbitrarily or inconsistently.

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Summary of Argument

The U.S. Supreme Court has recognized that children are different from adults and shouldn't be punished as harshly. In a recent case, Miller v. Alabama, the Court ruled that it's generally wrong to sentence young people to life in prison without the possibility of parole for murder. This ruling requires judges to consider a young person's age and other factors that could make them less guilty or more likely to be rehabilitated before sentencing them to life without parole.

Even though Miller dealt with mandatory life without parole sentences, the court's decision to require individualized hearings for young people facing this sentence also applies to cases where judges have the discretion to choose the punishment. Because Mr. Walker didn't have a hearing where his age and other characteristics were considered, his sentence should be overturned. This court should also provide clear guidelines to make sure that life without parole sentences for young people are not given out unfairly.

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Summary of Argument

The Supreme Court has said that kids are different from adults. They are less likely to commit another crime and are more likely to change as they grow.

In a case called Miller v. Alabama, the Supreme Court said that a judge should not automatically give a kid a life sentence without the possibility of parole for killing someone. Before doing so, the judge should consider the kid's age and whether they are likely to change their behavior.

Mr. Walker did not get a chance for the judge to consider these things, so his sentence should be changed. Judges should also make sure that they do not give out life sentences to kids without thinking about it carefully.

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Footnotes and Citation

Cite

Brief of Amici Curiae Juvenile Law Center, Civitas ChildLaw Clinic, and Campaign for the Fair Sentencing of Youth in Support of Petitioner-Appellant James Walker, People v. Walker, No. 3-14-0723 (Ill. App. Ct. June 8, 2015).

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