Brief of Amici Curiae National Association of Criminal Defense Lawyers, Mississippi Office of the State Public Defender, and Mississippi Public Defenders Association in Support of Petitioner
Barbara E. Bergman
Ginger D. Anders
André de Gruy
Teresa A. Reed Dippo
Justin Cook
SimpleOriginal

Summary

The Supreme Court has held that life without parole is appropriate only for a “permanently incorrigible” juvenile offender. States that do not require a finding of permanent incorrigibility are not reliably implementing that command.

2020 | Federal Juristiction

Brief of Amici Curiae National Association of Criminal Defense Lawyers, Mississippi Office of the State Public Defender, and Mississippi Public Defenders Association in Support of Petitioner

Keywords permanent incorrigible; incapable of rehabilitation; JLWOP; Miller; mitigating factor; disproportionate punishment; diminished culpability; lesser blameworthiness; Eighth Amendment (U.S.)
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Summary of Argument

Miller v. Alabama held that a court considering whether to sentence a juvenile to life without parole must “distinguish[] ... between ‘the juvenile offender whose crime reflects unfortunate yet transient imma- turity, and the rare juvenile offender whose crime re- flects irreparable corruption.’ ” 567 U.S. 460, 479–80 (2012) (quoting Roper v. Simmons, 543 U.S. 551, 573 (2005)). While the Court “d[id] not foreclose a sen- tencer’s ability to make th[e] judgment” that a juvenile is irreparably corrupt, thereby justifying a life-with- out-parole sentence, the Court warned that the sen- tence would be “uncommon”—because “children’s di- minished culpability” and “heightened capacity for change” create “great difficulty” in concluding, at the outset, that a child is beyond rehabilitation. Id.

Montgomery v. Louisiana confirmed that “irrepara- ble corruption” (or “irretrievable depravity,” or “per- manent incorrigibility”—terms the Court has used in- terchangeably) is a gating requirement for a constitu- tional sentence of life without parole for a juvenile of- fender. 136 S. Ct. 718, 733, 734 (2016). Montgomery explained that Miller announced a substantive rule because it “rendered life without parole an unconstitu- tional penalty for ‘a class of defendants because of their status’—that is, juvenile offenders whose crimes reflect the transient immaturity of youth.” Id. at 734 (quoting Penry v. Lynaugh, 492 U.S. 302, 330 (1989)). Consistent with precedent, that substantive rule was retroactive “because it necessarily carries a significant risk that a defendant—here, the vast majority of juve- nile offenders—faces a punishment that the law can- not impose.” Id. (quoting Schriro v. Summerlin, 542 U.S. 348, 352 (2004)) (alterations and quotation marks omitted).

Montgomery also addressed the procedural compo- nent of Miller’s rule, explaining that a sentencing hearing in which “youth and its attendant character- istics are considered” would be necessary to “separate those juveniles who may be sentenced to life without parole from those who may not.” 136 S. Ct. at 735 (ci- tation omitted). Addressing Louisiana’s argument that Miller did not require trial courts to make a fac- tual finding of permanent incorrigibility, the Court confirmed that it would “limit the scope” of procedural requirements that “intrud[e] more than necessary” on the States’ criminal justice systems. Id. At the same time, the substantive rule of Miller would be para- mount: States are not “free to sentence a child whose crime reflects transient immaturity to life without pa- role” because “this punishment is disproportionate un- der the Eighth Amendment.” Id.

Four years after Montgomery, states that do not re- quire a determination of permanent incorrigibility in order to sentence a child to life without parole are not reliably implementing the substantive rule of Miller. Mississippi cases illustrate the problems with that ap- proach. Generally speaking, Mississippi courts pre- sume a life-without-parole sentence is justified, and ei- ther avoid the question of permanent incorrigibility al- together, or require the juvenile offender to prove he will never reoffend. The resulting sentences of life without parole violate Miller’s substantive rule be- cause they do not rest on a finding that the offender is more likely than not “permanently incorrigible.”

The safeguard of a finding of permanent incorrigi- bility is necessary to ensure that juvenile offenders re- ceive life-without-parole sentences only when that sentence is proportionate and lawful. The finding re- quirement brings purpose and structure to a sen- tencer’s review of the juvenile offender’s individual- ized circumstances, ensuring that the sentencing anal- ysis is not overwhelmed by the heinousness of the crime, or by the potential risk of immediate release (a consideration that should be left to a later parole board). Sentencers retain discretion to impose life- without-parole sentences on juvenile offenders, but that discretion is properly bounded by “Miller’s central intuition—that children who commit even heinous crimes are capable of change.” Montgomery, 136 S. Ct. at 736.

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Summary of Argument

In Miller v. Alabama, the Supreme Court ruled that sentencing juvenile offenders to life without parole requires distinguishing between those exhibiting "transient immaturity" and the "rare" cases reflecting "irreparable corruption." While acknowledging sentencers' discretion in identifying irreparability, the Court cautioned that such sentences should be exceptional due to juveniles' reduced culpability and potential for rehabilitation.

Montgomery v. Louisiana affirmed "irreparable corruption" as a necessary condition for constitutional life sentences without parole for juveniles. Recognizing Miller as a substantive rule prohibiting such sentences for offenders whose crimes stem from "transient immaturity," Montgomery extended its retroactive application to mitigate the risk of unlawful punishment.

Montgomery also addressed procedural aspects, requiring sentencing hearings to consider youth-related factors and distinguish juveniles eligible for life without parole from those who are not. While acknowledging the need for flexibility, the Court emphasized that Miller's substantive rule takes precedence, precluding sentences for offenders whose crimes reflect transient immaturity.

In states that do not mandate a determination of permanent incorrigibility, the implementation of Miller's substantive rule is compromised. Mississippi cases demonstrate this, with courts presuming the appropriateness of life without parole and placing the burden on the juvenile to prove future non-offense. This approach violates Miller by imposing life sentences without establishing a likelihood of permanent incorrigibility.

The requirement for a finding of permanent incorrigibility is crucial to ensure proportionality and legality in sentencing juvenile offenders to life without parole. It structures the sentencing analysis, preventing it from being solely influenced by the crime's severity or the perceived risk of immediate release. While sentencers retain discretion, it is appropriately constrained by Miller's recognition of juveniles' capacity for change, even after heinous offenses.

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Summary of Argument

In the case of Miller v. Alabama, the court ruled that judges must distinguish between young offenders who commit crimes due to temporary immaturity and those rare cases where the crime shows permanent corruption. The court acknowledged that it might be possible to determine that a juvenile is beyond rehabilitation, but such a sentence of life without parole should be very uncommon due to the reduced blameworthiness and potential for change in young people.

Montgomery v. Louisiana further clarified that a finding of "irreparable corruption" is essential before a juvenile can be sentenced to life without parole. This rule was made retroactive, meaning it applied to past cases, because it protected juveniles from a punishment that is disproportionate to their level of culpability.

Montgomery also discussed the need for a sentencing hearing where the juvenile's youth and other factors are considered. However, the court emphasized that states have some flexibility in determining the procedures for such hearings, as long as the fundamental rule of Miller is followed: juveniles who commit crimes due to temporary immaturity cannot be sentenced to life without parole.

In states like Mississippi, where a determination of permanent incorrigibility is not required, the rule of Miller is often not followed. Courts tend to assume that life without parole is appropriate and may even require the juvenile to prove that they will not reoffend. This approach violates the rule of Miller because it does not ensure that the sentence is based on a finding that the offender is likely to be permanently incorrigible.

Requiring a finding of permanent incorrigibility provides a safeguard to ensure that life without parole is only given to juveniles when it is a fair and legal punishment. This requirement helps judges focus on the individual circumstances of the offender, rather than being swayed by the seriousness of the crime or the fear of immediate release. By doing so, the courts can ensure that even young people who commit serious crimes have a chance at rehabilitation, as recognized by the Supreme Court in Miller.

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Summary of Argument

In a court case called Miller v. Alabama, judges said that when deciding if a young person should get life in prison without the possibility of getting out, they need to tell the difference between kids who are still growing and changing and those rare kids who are so bad that they can never be fixed. Even though it's possible to sentence a kid to life without parole, the court said it should be very uncommon because kids are not as responsible for their actions as adults and they can change a lot.

Another case, Montgomery v. Louisiana, confirmed that in order for a kid to get life without parole, they must be proven to be "permanently incorrigible," meaning they can't ever be rehabilitated. This is because giving a kid life without parole is a very severe punishment that should only be used for those who deserve it.

Montgomery also said that there needs to be a hearing where the kid's age and other factors are considered to make sure that the punishment is fair. The court said that states can't just automatically give kids life without parole because they committed a bad crime.

But some states, like Mississippi, don't follow this rule. In Mississippi, courts often assume that kids deserve life without parole and don't properly consider whether the kid is really permanently incorrigible. This means that some kids are getting life sentences even though they don't deserve it.

It's important to make sure that kids who get life without parole actually deserve it. A finding of permanent incorrigibility helps to ensure that this severe punishment is only given to those who are truly beyond redemption. It also helps to make sure that kids who can change and become better people are not locked away forever.

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Summary of Argument

Sometimes kids and teens do very bad things, but it's important to remember that they're still kids. The law says that kids who do bad things should be punished, but not in the same way as adults. That's because kids are still growing and changing, and they might not fully understand why what they did was wrong.

In a special case called Miller v. Alabama, the court said that kids who do bad things should only be sentenced to life in prison without ever getting out if they are "beyond repair." This means that they would never be able to change and become better people. The court said that this kind of punishment should be very rare because most kids can change and improve.

Another case called Montgomery v. Louisiana made sure that kids who do bad things have a chance to show that they're not "beyond repair." This means that they have a hearing where they can talk about why they did what they did and what they've learned since then.

But some states don't follow these rules. In Mississippi, kids can be sentenced to life in prison without ever getting out, even if they're not "beyond repair." This is wrong because it's not fair to punish kids too harshly.

It's important to make sure that kids who do bad things are punished fairly. We need to give them a chance to show that they can change and become better people. That's why it's important to make sure that only kids who are truly "beyond repair" are sentenced to life in prison without ever getting out.

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Footnotes and Citation

Cite

Brief of Amici Curiae National Association of Criminal Defense Lawyers, Mississippi Office of the State Public Defender, and Mississippi Public Defenders Association in Support of Petitioner, Jones v. Mississippi, No. 18-1259 (U.S. Mar. 2018).

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