Summary of Argument

Over the past decade, the U.S. Supreme Court has held that children accused of committing crimes are different than adults in fundamental and constitutionally relevant ways. The Court has found that children who commit crimes, even violent crimes, are categorically less culpable than adults who commit similar crimes and may be deserving of lesser punishments. See Roper v. Simmons, 543 U.S. 551, 578 (2005) (holding that juveniles cannot receive the death penalty), Graham v. Florida, 560 U.S. 48, 82 (2010) (holding that juveniles non-homicide offensers cannot receive life without parole), and Miller v. Alabama, 132 S. Ct. 2455 (2013) (holding that juvenile homicide offenders cannot receive mandatory life without parole). Similarly, the Court has found that what is “reasonable” for an adult to foresee or perceive may not be “reasonable” for a juvenile in the same circumstances. See J.D.B. v. North Carolina, 131 S. Ct. 2394, 2399 (2011) (holding that determinations of “custody” for Miranda purposes, i.e., whether or not a “reasonable person” in the suspect’s position would feel free to leave, must take into account the age of the suspect). In reaching these conclusions, the Court has relied upon an increasingly settled body of research confirming the distinct emotional, psychological, and neurological attributes of youth. See Miller, 132 S. Ct. at 2464-65; J.D.B., 131 S. Ct. at 2403 n. 5; Graham, 560 U.S. at 68; Roper, 543 U.S. at 569-70.

This Court now has the opportunity to consider how this recent U.S. Supreme Court “children are different” jurisprudence impacts Indiana’s application of its felony murder doctrine to juveniles. Amici submit that broad application of Indiana’s felony murder statute to juvenile offenders fails to consider established research on adolescent development and brain science and conflicts with U.S. Supreme Court jurisprudence. This Court should grant the Petition to Transfer.

Summary of Argument

Over the past decade, the U.S. Supreme Court has recognized significant distinctions between children and adults in the context of criminal justice, particularly regarding culpability and legal judgments. The Court has consistently held that juveniles, even those who commit violent offenses, are less culpable than adults committing similar crimes. This view is rooted in the Court's acknowledgement of the unique developmental characteristics of youth, including their emotional, psychological, and neurological differences.

In several landmark cases, the Supreme Court has applied these principles to limit the severity of punishments for juveniles. Notably, the Court has prohibited the death penalty for juveniles (Roper v. Simmons), life without parole for juveniles who commit non-homicide offenses (Graham v. Florida), and mandatory life without parole for juvenile homicide offenders (Miller v. Alabama). The Court has also considered these developmental differences in assessing the "reasonableness" of a juvenile's perceptions, recognizing that a juvenile's understanding of situations may differ from an adult's (J.D.B. v. North Carolina).

These judicial decisions reflect a growing understanding of the distinct nature of youth, supported by a substantial body of research on the developmental trajectories of adolescents and young adults. This research has provided a scientific foundation for the Court's recognition that juveniles are not simply smaller versions of adults and deserve legal treatment that reflects their unique vulnerabilities and developmental stage.

Summary of Argument

The U.S. Supreme Court has recognized significant differences between adult and juvenile offenders in recent years. The Court has held that children are less culpable than adults and may require different punishments due to their unique developmental stage. These decisions are supported by scientific research demonstrating the distinct emotional, psychological, and neurological characteristics of youth. The Court has also considered the impact of these differences on an individual’s ability to perceive and respond to situations, particularly in the context of legal proceedings. Because of these difference, this Court must grant the Petition to Transfer.

Summary of Argument

The U.S. Supreme Court has recognized that children who commit crimes are different from adults. This means they may not be held responsible for their actions in the same way as adults. The Court has ruled that juveniles should not be given the death penalty, life sentences without parole for non-violent crimes, or mandatory life sentences without parole for violent crimes. The Court has also stated that what seems reasonable to an adult might not be reasonable to a child in the same situation. These decisions are based on research showing that teenagers' brains are still developing and that they are more impulsive and less able to control their emotions than adults. Because of this research, this Court should grant the Petition to Transfer.

Summary of Argument

The Supreme Court has decided that children who break the law are different from adults. They say that kids and teens aren't as responsible for their actions as adults, even if they commit a serious crime. The court also states that what seems normal to an adult might not seem normal to a child. They've used lots of studies to prove that kids' brains and how they feel are different from adults. Because of these studies, this Court should grant the Petition to Transfer.