Summary of Argument

Miller v. Alabama, 132 S. Ct. 2455 (2012) held that mandatory life without parole sentences are unconstitutional for juvenile homicide offenders. Following the Miller decision, Appellant Qu’eed Batts’ mandatory juvenile life without parole sentence was vacated. At Mr. Batts’ resentencing, the sentencing court reimposed life without parole. This second life without parole sentence fails to satisfy the holding and mandated considerations of Miller, however. It, too, must be vacated.

First, in concluding that juvenile life without parole sentences after Miller must be “uncommon,” Miller, 132 S. Ct. at 2469, Miller adopts a presumption against imposing juvenile life without parole sentences. The imposition of any juvenile life without parole sentence is suspect because there is no reliable way to identify the rare juvenile whose crime demonstrates irreparable corruption and for whom a life without parole sentence might therefore be appropriate. Second, because life without parole for a juvenile is akin to the death penalty for an adult, this Court must look to death penalty jurisprudence that reserves the harshest available sentence for the most heinous and depraved homicide offenders. Objective guidance is necessary to ensure that this harshest sentence available for juvenile offenders, if ever imposed, is only imposed in the most egregious cases and only upon irreparably corrupt individuals. Because no such guidance exists, the sentence was imposed in an arbitrary and capricious manner.

Finally, Miller requires that a sentencer examine specific factors and consider how those factors counsel against sentencing a juvenile to life without parole. Miller, Graham v. Florida, 560 U.S. 48 (2010), and Roper v. Simmons, 543 U.S. 551 (2005) collectively require that the circumstances of the offense – no matter how brutal or cold-blooded – not overpower evidence of mitigation based on youth. Moreover, the characterization of these factors themselves afford juveniles a presumption of immaturity. Application of these factors to Mr. Batts’ case, together with the adolescent development research at the core of Miller, demonstrate that Mr. Batts’ actions correlated closely with his age and psychosocial development, and therefore he should not receive the harshest available sentence.

Accordingly, this Court should vacate Mr. Batts’ juvenile life without parole sentence.

Summary of Argument

In Miller v. Alabama (2012), the Supreme Court held that mandatory life without parole sentences for juvenile homicide offenders violate the Eighth Amendment's prohibition against cruel and unusual punishment. Following this decision, Qu’eed Batts' initial mandatory sentence was vacated. However, upon resentencing, the court reimposed a life without parole sentence, which the present analysis argues is also unconstitutional under Miller.

Miller established a presumption against juvenile life without parole sentences, recognizing the difficulty in reliably identifying juveniles whose crimes demonstrate irreparable corruption. The Court emphasized that such sentences should be "uncommon."

Given the severity of life without parole for juveniles, the Court draws an analogy to death penalty jurisprudence. In capital cases, the harshest sentence is reserved for the most heinous offenders. Similarly, juvenile life without parole sentences should be imposed only in the most egregious cases and upon individuals who are irreparably corrupt.

Miller mandates that sentencers consider specific factors that mitigate against life without parole sentences for juveniles. These factors include the circumstances of the offense, which should not overshadow evidence of immaturity and psychosocial development.

Applying these factors to Batts' case, the analysis argues that his actions were consistent with his age and developmental stage. Therefore, he should not be subjected to the harshest available sentence.

Based on the principles established in Miller, the reimposed life without parole sentence for Qu’eed Batts is unconstitutional. The Court should vacate this sentence and consider alternative sentencing options that account for his youth and potential for rehabilitation.

Summary of Argument

In Miller v. Alabama (2012), the Supreme Court ruled that it is unconstitutional to sentence juveniles to life in prison without the possibility of parole. This decision was based on the idea that juveniles are different from adults and should not be given the same harsh punishments.

Qu’eed Batts' Case

Qu’eed Batts was sentenced to life without parole for a homicide he committed as a juvenile. After the Miller decision, his sentence was overturned. However, at his resentencing, the court reimposed the life without parole sentence.

Arguments for Vacating Batts' Sentence

There are several reasons why Batts' life without parole sentence should be vacated:

• Presumption Against Juvenile Life Without Parole: Miller established that such sentences should be rare and only imposed in exceptional cases.

• Comparison to Death Penalty: Life without parole for juveniles is similar to the death penalty for adults. Therefore, it should only be used for the most serious offenders.

• Consideration of Youthful Factors: Miller requires courts to consider factors related to youth, such as immaturity and potential for rehabilitation. These factors should have been weighed against the circumstances of Batts' offense.

Conclusion

Based on the principles established in Miller, Batts' life without parole sentence is unconstitutional. It fails to consider the presumption against such sentences, the severity of the punishment, and the mitigating factors related to his youth. Therefore, the sentence should be vacated.

Summary of Argument

In a court case called Miller v. Alabama, the judges ruled that it's not fair to automatically give juveniles life in prison without parole for murder.

After this ruling, a young man named Qu'eed Batts had his life sentence changed. But when he was sentenced again, he got life in prison without parole again.

Why This Sentence Is Unfair

• It's rare to give juveniles life without parole. It's hard to know which young people are so bad that they deserve this punishment.

• It's like the death penalty for adults. We only give the death penalty to the worst criminals. So, we should only give life without parole to the worst juvenile criminals.

• Judges need clear rules. Without rules, judges might give this punishment unfairly.

What the Court Should Consider

When sentencing juveniles, judges should consider:

• The crime itself. Even serious crimes shouldn't automatically lead to life without parole.

• The juvenile's age and maturity. Young people are still developing and may not fully understand their actions.

In Mr. Batts' case, the judges didn't consider these things carefully enough. He shouldn't have gotten the harshest punishment possible.

Therefore, Mr. Batts' life without parole sentence should be overturned.

Summary of Argument

Years ago, a teenager named Miller committed a serious crime and was sentenced to life in prison without the possibility of parole. This meant he would never be released. However, the Supreme Court later ruled that this was not fair. They said that juveniles are different from adults and shouldn't receive the same severe punishments. This case is known as Miller v. Alabama.

After this case, another teenager, Qu’eed Batts, went back to court to be sentenced again. But when he was re-sentenced, the court imposed the same life sentence without parole on him again. This is unfair because:

• It's hard to know which kids are actually bad. Kids' brains are still growing, and they don't always make good decisions.

• Life without parole is like the death penalty for kids. It's the worst punishment we can give them.

• The court didn't think about all the things that made Qu’eed different from an adult. He was young, and his brain wasn't fully developed.

The people writing this breif believe that Qu’eed's sentence should be taken away again. Kids deserve a chance to change and become better people.