Brief of Amici Curiae Oregon Justice Resource Center and Oregon Criminal Defense Lawyers Association
Ellen Rosenblum
Benjamin Gutman
Ernest Lannet
Marc D. Brown
Crystal Maloney
SimpleOriginal

Summary

Juvenile lifetime imprisonment sentences are unconstitutional under the Oregon Constitution and under the Eighth Amendment.

2020 | State Juristiction

Brief of Amici Curiae Oregon Justice Resource Center and Oregon Criminal Defense Lawyers Association

Keywords brain development; age 25; prefrontal cortex; cognition; developmental differences between juveniles and adults; brain imaging; neuroimaging; decision- making; immaturity; emotional control; impulse control; juvenile life imprisonment; Eighth Amendment (U.S.)
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Summary of Argument

The United States Supreme Court has long recognized that juveniles are cognitively and developmentally different than adults, acknowledging developments in psychology and brain science. Scientific research on brain development and psychosocial maturity shows that juveniles are less developed than adults. In fact, human brain development is a protracted series of processes that extends until near the age of 25. Most important to juvenile criminal sentencing, the prefrontal cortex remains underdeveloped through adolescence. And the prefrontal cortex controls the executive brain functions of decision making, impulse control, and emotional regulation. Those lacking functions cause adolescents to lack the capacity to envision long-term consequences and to resist peer pressure.

Because of adolescents’ brain development, juvenile lifetime imprisonment sentences, including those that allow eligibility for parole after 30 years, fail to serve the purposes of punishment. Specifically, such sentences do not further the causes of defendant rehabilitation or public protection. Long-term imprisonment of juveniles works against rehabilitation, because prisons are inherently stressful environments that can negatively alter neural systems, especially those of developing brains. Furthermore, it is well documented that juveniles “age out of crime,” likely meaning their risk-taking behavior ceases when their brains are fully developed. Therefore, a juvenile’s prison sentence will also cease to serve the purpose of public protection when the juvenile matures into adulthood.

In light of the science of juvenile brain development, this court should hold that juvenile lifetime imprisonment sentences, including those with the possibility of parole after 30 years of imprisonment, are unconstitutional under Article I, section 16, of the Oregon Constitution and under the Eighth Amendment to the United States Constitution.

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Summary of Argument

The United States Supreme Court has consistently recognized the cognitive and developmental distinctions between juveniles and adults, acknowledging advancements in psychology and neuroscience. Scientific research on brain development and psychosocial maturity indicates that juveniles exhibit a lesser degree of development than adults. Human brain development is a protracted series of processes that continues until approximately the age of 25. Particularly relevant to juvenile criminal sentencing, the prefrontal cortex remains underdeveloped throughout adolescence. This brain region is responsible for executive functions, including decision-making, impulse control, and emotional regulation. Deficiencies in these functions result in adolescents lacking the capacity to anticipate long-term consequences and resist peer pressure.

Due to the ongoing development of the adolescent brain, juvenile lifetime imprisonment sentences, including those that allow eligibility for parole after 30 years, fail to achieve the objectives of punishment. Specifically, such sentences do not contribute to defendant rehabilitation or public protection. Long-term incarceration of juveniles impedes rehabilitation because prisons are inherently stressful environments that can negatively affect neural systems, particularly those of developing brains. Moreover, it is well documented that juveniles "age out of crime," suggesting that their risk-taking behavior diminishes as their brains mature. Consequently, a juvenile's prison sentence will no longer serve the purpose of public protection upon the juvenile's transition into adulthood.

In light of scientific evidence regarding juvenile brain development, this court should conclude that juvenile lifetime imprisonment sentences, including those with the possibility of parole after 30 years of imprisonment, are unconstitutional under Article I, section 16, of the Oregon Constitution and the Eighth Amendment to the United States Constitution.

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Summary of Argument

The United States Supreme Court has long recognized that juveniles are cognitively and developmentally different from adults. This understanding is based on advancements in psychology and brain science, which show that the human brain continues to develop until around the age of 25. Specifically, the prefrontal cortex, responsible for executive functions like decision-making, impulse control, and emotional regulation, is still maturing throughout adolescence. This lack of development makes it difficult for adolescents to consider long-term consequences or resist peer pressure.

Juvenile lifetime imprisonment sentences, even those with potential parole after 30 years, fail to align with the goals of punishment, rehabilitation, or public safety. Imprisonment itself is a stressful environment that can negatively impact developing brains, hindering rehabilitation. Additionally, the well-documented phenomenon of juveniles “aging out of crime” suggests that their risk-taking behaviors decline as their brains mature. Therefore, prolonged imprisonment for juveniles beyond their developmental stage does not effectively address the need for public protection.

Given the scientific evidence of juvenile brain development, this court should find that juvenile lifetime imprisonment sentences, even with parole options, are unconstitutional under both the Oregon Constitution and the Eighth Amendment to the U.S. Constitution.

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Summary of Argument

The Supreme Court has long recognized that teenagers are different from adults. They're still developing their brains, especially the part that helps them make good decisions, control their impulses, and manage their emotions. This part of the brain, called the prefrontal cortex, doesn't fully mature until around age 25. This means that teenagers are less capable of thinking about the long-term consequences of their actions and are more likely to give in to peer pressure.

Because of their developing brains, sentencing teenagers to life in prison, even with the possibility of parole after 30 years, doesn't make sense. It doesn't help them get better or protect the public. In fact, prison can be a very stressful environment, especially for young brains still developing. It's also been shown that teenagers are less likely to commit crimes as they get older, once their brains are fully developed. So, keeping a teenager in prison for a very long time won't actually keep the public safe once they're older.

Based on what we know about how teenage brains develop, the court should rule that sentencing teenagers to life in prison, even with the chance of parole after 30 years, is unconstitutional. This is because it violates the Oregon Constitution and the Eighth Amendment of the U.S. Constitution, both of which protect individuals from cruel and unusual punishment.

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Summary of Argument

Kids’ brains are still growing and changing until they are about 25 years old. The part of the brain that helps people make good decisions, control their impulses, and manage their feelings isn’t fully developed until then. This means that teens might not be able to think about the long-term consequences of their actions or resist pressure from their friends.

Because of how kids’ brains develop, putting a kid in prison for life, even if they can get out after 30 years, isn’t a good idea. It doesn’t help them get better, and it doesn’t keep people safe. Prison is a stressful place, and it can be bad for a developing brain. Also, most kids don’t keep getting into trouble as they get older. They usually grow out of it when their brains are fully developed. So, putting a kid in prison for life won’t be necessary to keep people safe once they’re adults.

This court should decide that putting a kid in prison for life is against the law, according to the Oregon Constitution and the U.S. Constitution.

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Footnotes and Citation

Cite

Brief of Amici Curiae Oregon Justice Resource Center and Oregon Criminal Defense Lawyers Association in Support of Defendant-Appellant Justin Alan Link, State v. Link, No. S066824 (Or. Feb. 21, 2020).

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