Summary of Argument
Amicus Juvenile Law Center writes in support of Appellant’s motion for panel rehearing or, in the alternative, rehearing en banc on the question as to whether Appellant’s life without parole sentence violates the Supreme Court’s holdings in Miller v. Alabama, 132 S. Ct. 2455 (2012).
Miller reaffirms the U.S. Supreme Court’s recognition that children are fundamentally different from adults and categorically less deserving of the harshest forms of punishments. Miller requires the sentencer to make an individualized sentencing determination based on a juvenile's overall culpability. The scope and extent of the holding in Miller is a critical national issue and requires thorough briefing and consideration.