Summary of Argument

In 2005, Cyntoia Brown was a sixteen-year-old with a Fetal Alcohol Spectrum Disorder diagnosis when she was convicted of first-degree murder and sentenced to a mandatory term of life imprisonment. Tenn. Code Ann. § 39-13-202(c). Although the Tennessee Court of Criminal Appeals held that Cyntoia may be eligible for parole after serving 51 years of her sentence, a Tennessee Court of Appeals decision strongly calls into question whether she would ever be eligible for parole. See Brief of Appellant pp. 17-19. Even if she may request parole at age 68, her sentence unquestionably deprives her of a “meaningful opportunity to obtain release.” See generally Brief of Amicus Curiae, American Civil Liberties Union of Tennessee in Support of Appellant.

A meaningful opportunity for release must mean more than release in the twilight of one’s life with limited opportunity to experience life outside prison walls or to make meaningful contributions to one’s community. Eighth Amendment jurisprudence has clarified that the constitutionality of a sentence depends on the actual impact of the sentence upon the individual, not how a sentence is labeled. Sumner v. Shuman, 483 U.S. 66, 83 (1987). A sentence that merely offers geriatric release or, in the alternative, ensures that Cyntoia will die in prison is a mandatory life sentence that is disproportionate when imposed on a sixteen-year old.

Summary of Argument

In the case of Cyntoia Brown, a 16-year-old diagnosed with Fetal Alcohol Spectrum Disorder, the constitutionality of her mandatory life imprisonment sentence has been brought into question.

Legal Context

Under Tennessee law (Tenn. Code Ann. § 39-13-202(c)), Brown was convicted of first-degree murder and sentenced to life imprisonment. While the Tennessee Court of Criminal Appeals ruled that she could be eligible for parole after 51 years, a subsequent decision casts doubt on this possibility.

Meaningful Opportunity for Release

The Eighth Amendment requires that juvenile offenders have a "meaningful opportunity to obtain release." This does not merely imply release at an advanced age, but rather a chance to experience life outside prison and contribute to society.

Impact on the Individual

In determining the constitutionality of a sentence, courts consider its impact on the individual. A sentence that offers only geriatric release or ensures that Brown will die in prison is effectively a mandatory life sentence, which is disproportionate for a 16-year-old offender.

Summary of Argument

In 2005, 16-year-old Cyntoia Brown, who had been diagnosed with Fetal Alcohol Spectrum Disorder, was found guilty of murder and sentenced to life in prison without the possibility of parole for 51 years.

Although a court later ruled that Brown could apply for parole after serving 51 years, it is uncertain whether she would actually be granted release. Even if she is eligible for parole at age 68, her sentence effectively denies her a "meaningful opportunity to obtain release."

A meaningful chance at release should not simply mean being freed in old age, with little chance to live a fulfilling life outside of prison. The Eighth Amendment of the Constitution protects against cruel and unusual punishment, and courts have ruled that the impact of a sentence on an individual must be considered.

For a 16-year-old like Cyntoia Brown, a life sentence without a meaningful chance at release is disproportionately harsh. It denies her the opportunity to make amends for her actions and contribute to society.

Summary of Argument

In 2005, 16-year-old Cyntoia Brown, who had a medical condition called Fetal Alcohol Spectrum Disorder, was found guilty of murder and sentenced to life in prison without the possibility of parole for 51 years.

Even though Cyntoia might be able to ask for parole when she's 68, it's not clear if she'll ever get it. And even if she does, she'll have spent most of her life behind bars. This is unfair because:

• A "meaningful opportunity for release" means more than just getting out of prison when you're old and have little time left to live.

• The law says that a sentence should be based on how it affects the individual, not just what the sentence is called.

• A sentence that keeps Cyntoia in prison until she's old or dies is basically a life sentence without parole, which is too harsh for a 16-year-old.

Summary of Argument

In 2005, Cyntoia Brown was 16 years old when she was found guilty of murder. She was given a very long sentence of at least 51 years.

Even though she is able to ask to leave prison when she is 68 years old, it's not clear if she will ever be allowed to go free. That's because her sentence is so long that she might not have much time left to live outside of prison.

Some people believe that her sentence is unfair because she was only 16 when she committed the crime. They say that a sentence that keeps someone in prison for so long, or even until they die, is too harsh for a young person. They think that everyone should have a chance to leave prison and make a better life for themselves, even if they have done something wrong.