Summary of Argument

Bobby Bostic’s judge sentenced him to die inprison for nonhomicide offenses he committed at age 16. He will not become eligible for parole until he is 112 years old. Mr. Bostic’s sentence violates Graham v. Florida, 560 U.S. 48 (2010), because he will spend his life in prison without a meaningful opportunity to obtain release.

Graham held that sentences of life without possibility of parole for juvenile nonhomicide offenders violate the Eighth Amendment. It recognized that for such juveniles, their capacity for change and limited moral culpability prohibits irrevocably condemning them to die in prison. For that reason, states must provide them a “meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation.” Id. at 75. The overwhelming weight of authority favors applying Graham to juveniles sentenced to aggregate term-of-years sentences exceeding their lifespan. Missouri has joined the small number of jurisdictions limiting Graham to juvenile nonhomcide offenders who have received a formal sentence of life without possibility of parole for a single offense.

Amici’s core argument—that juveniles are different from adults and should be treated accordingly even when sentenced to aggregate terms-of-years under multiple-count indictments—is supported by their collective centuries of experience. As former judges and prosecutors, amici have personally considered the total sentence in deciding what charges to file and whether to run sentences consecutively or concurrently. These decisions are made in light of the substance of the sentence imposed, not whether it is formally labeled life without parole. Although the Court has approved of that practice for adults, where a life without parole sentence is constitutional, the practice of crafting sentences that guarantee a juvenile nonhomicide offender will die in prison violates at least the spirit of Graham.

Mr. Bostic’s case epitomizes the rationale underlying the Court’s decision in Graham. After decades in prison following the “impetuous and ill- considered actions and decisions” he made at age 16, Mr. Bostic has grown and matured. But Missouri law does not afford him the opportunity to ever “demonstrate that he is fit to rejoin society.” The Court should grant certiorari and reverse the decision of the Missouri Supreme Court.

Summary of Argument

Bostic's sentence, imposed for nonhomicide offenses committed as a juvenile, mandates his death in prison without eligibility for parole until the age of 112. This contravenes the Eighth Amendment, as established in Graham v. Florida (2010). Graham prohibits life sentences without parole for juvenile nonhomicide offenders, acknowledging their potential for rehabilitation and reduced moral culpability.

The majority of legal authorities extend Graham's protections to juveniles facing aggregate term-of-years sentences that effectively amount to life without parole. However, Missouri has adopted a narrow interpretation, limiting Graham to cases where a formal life sentence is imposed for a single offense.

Amici, drawing upon their extensive legal experience, argue that the distinction between formal and effective life sentences is immaterial. They emphasize that juveniles possess distinct characteristics that warrant differential treatment, regardless of the technicalities of sentencing. The rationale behind Graham applies equally to juveniles facing sentences that ensure their death in prison.

Bostic's case exemplifies this rationale. Despite decades of growth and maturation since his youthful offenses, Missouri law denies him any opportunity to demonstrate his readiness for societal reintegration. This violates the spirit of Graham, which mandates a meaningful chance for release based on proven rehabilitation. Therefore, the Supreme Court should grant certiorari and overturn the Missouri Supreme Court's decision, upholding the principle that juvenile nonhomicide offenders deserve a chance at redemption.

Summary of Argument

When Bobby Bostic was 16, he committed several non-homicide crimes and was sentenced to an extremely long prison term that effectively guarantees he will die behind bars. His case raises the question of whether such harsh sentences for juvenile offenders are constitutional.

In the landmark case Graham v. Florida, the Supreme Court ruled that sentencing juveniles to life in prison without the possibility of parole for non-homicide offenses violates the Eighth Amendment, which prohibits cruel and unusual punishment. The Court recognized that juveniles have a greater capacity for change and are less morally culpable than adults, making it inappropriate to condemn them to a lifetime behind bars.

Most courts have agreed that the principles of Graham apply to juveniles sentenced to long prison terms that add up to life in prison, even if they don't receive a formal life sentence. However, Missouri is among a few states that have refused to extend Graham to such cases.

Bostic's supporters argue that the spirit of Graham should apply to all juvenile non-homicide offenders, regardless of how their sentences are structured. They emphasize that courts consider the total length of a sentence when making sentencing decisions, and that sentencing juveniles to life in prison through multiple sentences is just as severe as a single life sentence.

Bostic has spent decades in prison and has reportedly matured and changed significantly. However, Missouri law does not give him a meaningful opportunity to demonstrate his rehabilitation and earn release. His case highlights the need for the Supreme Court to clarify whether Graham applies to all juvenile non-homicide offenders who will effectively spend their lives in prison.

Summary of Argument

Bobby Bostic was only 16 when he went to prison. The judge gave him a sentence that means he'll be locked up until he's 112 years old, even though he didn't kill anyone. This sentence goes against a rule made by the Supreme Court in a case called Graham v. Florida.

Graham v. Florida says that it's cruel and unusual punishment to sentence kids who didn't commit murder to life in prison without the chance to get out. The reason is that kids are still developing and can change for the better. They deserve a chance to show that they've grown and deserve to be released.

Most states agree that this rule should apply to kids like Bobby Bostic, who are sentenced to many years in prison that add up to more than their life expectancy. But Missouri is one of the few states that doesn't think so.

Former judges and prosecutors, who have a lot of experience with these cases, argue that kids are different from adults and should be treated differently. They say that even if a kid gets sentenced to multiple charges that add up to a lot of time, it's still not fair to guarantee that they'll die in prison without a chance to prove they've changed.

Bobby Bostic's case is a good example of why the Graham rule is important. After spending many years in prison, he's matured and become a better person. But Missouri law doesn't give him the chance to show that he's ready to be a part of society again. The Supreme Court should take up his case and fix this injustice.

Summary of Argument

When Bobby Bostic was 16, he committed crimes, but did not kill anyone, and was sent to jail for life. That's not fair because the law says that kids who commit crimes should have a chance to change and get out of jail when they're older.

When kids do wrong things, they don't think as clearly as adults. They also don't deserve to be punished as harshly as adults. That's why the law says kids like Bobby should have a chance to show they've grown up and learned from their mistakes.

Bobby has been in jail for many years now. He's not the same kid who made those bad choices. He's grown up and changed. But because of Missouri's law, he'll never get a chance to prove that he deserves to be free.

Some people say that Bobby's punishment is okay because he wasn't sentenced to life in prison for just one crime. But that doesn't matter. The important thing is that he'll never get out of jail. That's just as bad as life in prison without parole.

We think the law should be changed so that kids like Bobby have a real chance to change and get out of jail. They deserve a second chance.