Brief of Amicus Curiae Amicus Populi in Support of Respondent
Mitchell Keiter
SimpleOriginal

Summary

A court need not find irretrievable depravity, permanent incorrigibility, or irreparable corruption before sentencing a juvenile murderer to LWOP.

2020 | Federal Juristiction

Brief of Amicus Curiae Amicus Populi in Support of Respondent

Keywords Eighth Amendment (U.S.); permanently incorrigible; juvenile life without parole; JLWOP; juvenile murderer; permanent incorrigibility; irreparable corruption; irretrievable depravity; beyond rehabilitation; Miller
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Summary of Argument

This case illustrates Yogi Berra’s wisdom in observing “it is hard to make predictions, especially about the future.” After a jury convicts a juvenile of murder, sentencers in most states must make an individualized determination about whether to sentence the defendant to life imprisonment without possibility of parole (LWOP) or some lesser sentence. An LWOP sentence denies the juvenile the chance to demonstrate growth and maturity, and alters his life with a forfeiture that is irrevocable. Graham v. Florida, 560 U.S. 48, 69, 73 (2010). But a juvenile murderer who is later released and repeats his crime produces the death of an innocent person. As with COVID-19, both over-confinement and under-confinement impose social costs.

Courts must therefore sort those who deserve a chance for release from those who warrant permanent confinement. This Court has described the former as juvenile offenders whose crimes reflect “transient immaturity” and the latter as those whose character reflects “irreparable corruption” or “irretrievable depravity.” Miller v. Alabama, 567 U.S. 460, 471, 479- 80 (2012). The imperative of preventing cruel and unusual punishment requires the former have an opportunity for release. The imperative of protecting human life requires the latter never again have the opportunity to prey upon the public.

The sentencer’s determination concerns a prediction about the future, but must turn on facts discernible in the present. Objective factors like the “character and record of the individual offender” and the “circumstances of the particular offense” rather than subjective ones have long informed the decision whether to impose a discretionary maximum sentence in both capital and noncapital proceedings. Woodson v. North Carolina, 428 U.S. 280, 302-05 (1976) (plurality opinion); Graham, 560 U.S. at 87 (Roberts, C.J., concurring); see also Solem v. Helm, 463 U.S. 277 (1983). These current, objective factors can and should govern the sentencing of juvenile murderers.

The decision in Miller v. Alabama, 567 U.S. 460 (2012) broke new ground as the first to diverge from the principle that “death is different.” Prior cases had applied special scrutiny when the penalty was death (Lockett v. Ohio, 438 U.S. 586 (1978); Woodson, 428 U.S. 280), or when the punishment was permanent (LWOP) but the crime did not inflict death. Graham, 560 U.S. 48; Solem, 463 U.S. 277. Miller was the first case to apply that scrutiny to a noncapital sentence punishing a capital crime. Nonetheless, the same factors, objectively discernible to the sentencer at the time of conviction, must govern the sentencing choice.

Miller had a prescriptive component, as it held the “Eighth Amendment forbids a sentencing scheme that mandates life in prison without possibility of parole for juvenile offenders.” Miller, 567 U.S. at 479. It had a predictive component: “[W]e think appropriate occasions for sentencing juveniles to this harshest possible penalty will be uncommon.” Id, emphasis added. And there was a descriptive component, recalling the “great difficulty . . . of distinguishing at this early age between ‘the juvenile offender whose crime reflects unfortunate yet transient immaturity, and the rare juvenile offender whose crime reflects irreparable corruption.’ Id. at 479-80, quoting Roper v. Simmons, 543 U.S. 551, 573 (2005).

This latter contrast did not compel sentencers to determine before imposing an LWOP sentence whether the defendant acted out of irreparable corruption, or “irretrievable depravity.” If it had, a jury, not a court, would need to make that determination. United States v. Haymond, 139 S. Ct. 2369, 2379 (2019). Furthermore, the contrasts between adults and juveniles concerning maturity, vulnerability, and character permanence involve differences of degree rather than kind. Roper concluded these general contrasts preclude categorizing juveniles among the worst offenders, who deserve death, but even if certain traits render adults more culpable generally, irretrievable depravity is not a prerequisite for imposing a death sentence on adult offenders. It is not necessary for an LWOP sentence for juveniles.

Most importantly, irretrievable depravity is not an intelligible standard for a sentencer, who can assess the present magnitude of depravity but not its future duration. Sentencing defendants based not on what they have done but on what the sentencer thinks they will do in the future inevitably entails speculation, which can implement unfair bias. Buck v. Davis, 137 S. Ct. 759, 776 (2017). When this Court first described the contrast between transient immaturity and irreparable corruption, it was to cite a contrast that even experts could not be expected to make. Roper, 543 U.S. at 573. Insofar as imprisonment seeks not to punish offenses but to reform offenders, as the 1931 Wickersham Commission observed, it is no more possible to predict when (or if) an offender will be released from prison than to predict when a medical patient will be released from a hospital. Ilene H. Nagel, Structuring Sentencing Discretion: The New Federal Sentencing Guidelines, 80 J. Crim. L. & Criminology 883, 893 n.62 (1990). Sentencers must therefore decide based on objective, current facts, not speculation about which defendants will mature and which will remain incorrigible forever.

The standard cannot be that anyone with any possibility of reform must receive an opportunity for parole, so that only juveniles certain to re-offend may receive an LWOP sentence; everyone poses a risk of less than one hundred percent but more than zero percent of future crime. This Court has not extended Atkins v. Virginia, 536 U.S. 304 (2002), to restrict LWOP sentences for mentally impaired murderers, because the same factors rendering them less culpable may also render them more dangerous in the future. Similarly, even if it is harsher punishment to permanently incarcerate a teenager than a senior citizen, it provides a greater incapacitative protection for society. Determining which juveniles should be exempt from LWOP, like determining which mentally incompetent offenders should be exempt from capital punishment, is a project for democratic self-governance rather than constitutional law. Kahler v. Kansas, 140 S. Ct. 1021, 1037 (2020).

States must act to prevent false positive findings (whereby offenders remain incarcerated even though they would not re-offend), and false negatives (whereby offenders are released from custody but do re-offend). The former can wrongly take the liberty of the guilty, whereas the latter can wrongly take the lives of the innocent. Because the Constitution entrusts the state to protect people’s safety in the face of uncertain danger, courts should not micromanage the decisions of elected officials in protecting human life. South Bay United Pentacostal Church v. Newsom, 140 S. Ct. 1613, 1613-14 (2020) (Roberts, C.J., concurring in denial for injunctive relief.)

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Summary of Argument

Sentencing juvenile murderers presents a complex challenge, requiring courts to balance the potential for rehabilitation with the need to protect society. In Miller v. Alabama (2012), the Supreme Court recognized the inherent differences between juveniles and adults and held that mandatory life imprisonment without parole (LWOP) sentences for juveniles violate the Eighth Amendment's prohibition against cruel and unusual punishment. However, the Court also acknowledged the imperative of protecting human life and the need to confine those who pose an ongoing threat to society.

Objective Factors in Sentencing

The determination of whether a juvenile murderer deserves an opportunity for release or permanent confinement should be based on objective factors discernible at the time of sentencing. These factors include the character and record of the offender, as well as the circumstances of the offense. In both capital and noncapital cases, courts have long considered such factors in determining whether to impose discretionary maximum sentences.

The Predictive Component of Miller

Miller held that LWOP sentences for juveniles should be "uncommon." The Court recognized the difficulty in distinguishing between juveniles whose crimes reflect "transient immaturity" and those whose crimes reflect "irreparable corruption." However, the Court did not require sentencers to make a definitive determination of irreparable corruption before imposing an LWOP sentence.

The Problem of Irretrievable Depravity

The concept of irretrievable depravity is problematic as a sentencing standard because it is inherently speculative. Sentencers cannot reliably predict whether an offender will remain incorrigible forever. Sentencing based on such speculation can lead to unfair bias and undermine the rehabilitative purpose of imprisonment.

Balancing Rehabilitation and Protection

States must balance the potential for rehabilitation with the need to protect society from dangerous individuals. The Constitution entrusts states with the responsibility of protecting human life, and courts should not micromanage the decisions of elected officials in this regard. The goal should be to minimize both false positives (incarcerating offenders who would not re-offend) and false negatives (releasing offenders who do re-offend).

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Summary of Argument

Sentencing juvenile murderers is a difficult task because it involves predicting their future behavior. Judges must decide whether to give them a chance at parole or sentence them to life in prison without parole (LWOP).

The Challenge of Prediction

An LWOP sentence denies the juvenile the opportunity to show growth and change, but releasing a juvenile murderer who later commits another crime can cost innocent lives. Courts must therefore try to identify those who deserve a chance at release from those who should be permanently confined.

Factors to Consider

Courts consider objective factors such as the juvenile's character, record, and the circumstances of the crime. These factors can help predict whether the juvenile's crime was a result of temporary immaturity or permanent corruption.

The Miller Decision

In Miller v. Alabama, the Supreme Court ruled that LWOP sentences for juvenile offenders are unconstitutional in most cases. The Court recognized that juveniles are generally less mature and more vulnerable than adults, and that it is difficult to predict which juveniles will become irredeemable criminals.

The Difficulty of Determining Irredeemability

The concept of "irreparable corruption" is not a clear standard for judges to use. It is impossible to predict with certainty whether a juvenile will remain incorrigible forever. Judges must therefore rely on objective factors that are available at the time of sentencing.

Balancing Risks

States must balance the risk of keeping innocent people in prison with the risk of releasing dangerous criminals. The Constitution gives states the power to protect their citizens, and courts should not interfere with their decisions unless there is a clear constitutional violation.

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Summary of Argument

When a young person is found guilty of murder, judges have a difficult decision to make. Should they sentence the person to life in prison without the possibility of parole (LWOP), or give them a chance at release later on?

It's hard to predict the future. Judges can't know for sure if a young murderer will change and become a better person, or if they will always be a danger to society. If they give the person an LWOP sentence, they might be keeping someone in prison who could have turned their life around. But if they release the person and they commit another crime, innocent people could be hurt.

The Supreme Court has said that there are two types of young murderers:

  • Those who commit crimes because they are still immature and not fully responsible for their actions

  • Those who are so dangerous that they should never be released from prison

Judges have to look at the facts of each case and decide which type of person the young murderer is. They consider things like the person's age, background, and the details of the crime.

Judges should not try to predict the future. Instead, they should focus on the facts that they know right now. They should not sentence someone to LWOP just because they think the person might be dangerous in the future.

The government has a responsibility to protect people from danger. Judges should not release young murderers who they believe are a threat to society.

Sentencing young murderers is a difficult task. Judges have to balance the need to protect society with the possibility that the person could change and become a valuable member of society.

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Summary of Argument

What happens when a young person commits a serious crime like murder?

Judges have to decide if the young person should be locked up for life without ever getting out (called LWOP) or given a shorter sentence. It's a tough decision because:

  • Locking them up for life means they won't have a chance to grow and change.

  • But if they're released and commit another crime, someone innocent could get hurt.

How do judges decide?

Judges look at things like:

  • The young person's character and past behavior

  • What happened when they committed the crime

They try to figure out if the young person's crime was a sign of a bad character that won't change or just a mistake made because they were young and immature.

It's not easy to predict the future

Judges can't know for sure if a young person will change or if they'll always be dangerous. So they have to make their best guess based on what they know now.

The goal is to be fair and protect people

Judges want to give young people who deserve it a chance to turn their lives around. But they also have to make sure that people are safe from those who might hurt them.

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Footnotes and Citation

Cite

Brief Amicus Curiae of Amicus Populi in Support of Respondent, Jones v. Mississippi, No. 18-1259 (U.S. 2020).

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