Summary of Argument

The Eighth Amendment prohibits the sentence of life without the possibility of parole for all but the rarest of juvenile offenders. That is, “Miller [v. Alabama, 567 U.S. 460 (2012)] drew a line between children whose crimes reflect transient immaturity and those rare children whose crimes reflect irreparable corruption.” Montgomery v. Louisiana, 136 S.Ct. 718, 734 (2016). Thus, Miller provided a categorical rule: only those who are irreparably corrupt may be lawfully sentenced to life without the possibility of parole. In a decision that may affect scores of inmates serving life without the possibility of parole for juvenile offenses,2 the majority affirmed a sentence imposed without assessing Briones’ categorical eligibility for such a punishment.

Properly making that assessment should have included, at a minimum, an explicit finding of categorical eligibility. Holding otherwise risks rendering Miller’s primary protection meaningless. See Hall v. Florida, 134 S.Ct. 1986, 1999 (2014). Moreover, because only those juveniles who are irreparably corrupt are eligible for life without the possibility of parole, it is the state’s burden to prove as much to a jury beyond a reasonable doubt. See Apprendi v. New Jersey, 530 U.S. 466, 491-92 (2000). The panel’s contrary decision allows Briones’ improper sentence to stand.

Briones’ conviction is also unconstitutional. For juveniles, the statute authorizing his sentence provides only for mandatory life without the possibility of parole. Because Congress has not authorized a valid punishment for the charged crime, his conviction is also unconstitutional. See United States v. Evans, 333 U.S. 483, 486 (1948). In light of each of these substantial infirmities in the proceedings, Amici urge the Court to grant rehearing en banc.

Summary of Argument

The Eighth Amendment prohibits the imposition of life sentences without parole for juvenile offenders, except in cases of "irreparable corruption" (Montgomery v. Louisiana, 2016). This principle, established in Miller v. Alabama (2012), recognizes the transient nature of juvenile immaturity and the potential for rehabilitation.

In a recent decision, the court affirmed a life sentence without parole for Briones, a juvenile offender, without explicitly assessing his categorical eligibility for such a punishment. This raises concerns about the potential erosion of Miller's protections, as it allows for the possibility of imposing this severe sentence on juveniles who may not meet the criteria of irreparable corruption.

Furthermore, the court's decision places the burden of proving irreparable corruption on the defendant, contrary to the established principle in Apprendi v. New Jersey (2000) that such determinations must be made by a jury beyond a reasonable doubt. This departure from legal precedent further undermines the safeguards intended to protect juvenile offenders.

Additionally, Briones' conviction raises constitutional concerns. The statute authorizing his sentence mandates life without parole, leaving no room for individualized sentencing considerations. This violates the principle established in United States v. Evans (1948) that punishment must be authorized by Congress.

In conclusion, the court's decision in Briones' case raises significant concerns regarding the erosion of Eighth Amendment protections for juvenile offenders, the improper shifting of the burden of proof, and the constitutionality of the sentence imposed. These issues warrant further review and consideration by the court en banc to ensure the proper application of legal principles and the protection of juvenile offenders' rights.

Summary of Argument

The Eighth Amendment of the Constitution states that it is illegal to sentence juvenile offenders to life in prison without the possibility of parole, except in the rarest cases. This rule is based on the idea that most juveniles who commit crimes are not permanently bad people, but rather are still developing and have the potential to change.

In the case of Briones, the court did not properly determine whether he was one of the rare cases where a life sentence without parole was appropriate. The court should have made a specific finding that Briones was permanently corrupt and could not be rehabilitated. Without this finding, Briones' sentence is unconstitutional.

Furthermore, the law that authorized Briones' sentence is also unconstitutional. It only allows for a mandatory sentence of life without parole for juveniles, which is not a valid punishment for all juvenile offenders.

These issues are significant and could affect many other inmates who are currently serving life sentences without parole for crimes they committed as juveniles. The court should reconsider Briones' case and ensure that the proper procedures are followed in determining whether juvenile offenders are eligible for such severe punishments.

Summary of Argument

The law says that kids who commit crimes should only get life in prison without parole (never being released) in the rarest cases. This is because kids' brains are still developing, and they might not fully understand the consequences of their actions.

In a recent case, a young man named Briones was given life without parole even though the judge didn't say he was one of those rare cases where it's okay to give a kid that sentence. This is a problem because it means that kids who don't deserve such a harsh punishment might end up getting it.

It's also important to note that it's up to the government to prove that a kid deserves life without parole. They have to show that the kid is beyond help and will never be able to change.

Additionally, the law that allowed Briones to be sentenced to life without parole is not valid. It only allows for that sentence, and there is no other punishment available for the crime he was charged with. This means that his conviction is unfair.

Because of these problems, it's important for the court to reconsider Briones' case and make sure that kids are only given life without parole in the rarest and most extreme cases.

Summary of Argument

Most kids and teens who commit crimes shouldn't be sentenced to life in jail without a chance of getting out. Only the worst kids, who can't be helped, should get this punishment. There was a case where a kid named Briones got this sentence, even though the judge didn't make sure he was one of those really bad kids.

It's important to make sure that only the worst kids get this punishment. The judge should have to say that Briones was one of those kids. And it's up to the government to prove that he is, just like they have to prove someone is guilty of a crime. But in Briones' case, they didn't do that.

There's also a problem with the law that Briones was charged under. It says that kids who commit certain crimes have to get life in jail without a chance of getting out. But that's not fair, because not all kids who commit those crimes are bad enough to deserve that punishment. So Briones shouldn't have been sentenced that way.