Brief of Amicus Curiae Juvenile Law Center in Support of Petitioner-Appellee Luis Noel Cruz and Affirmance
Marsha L. Levick
SummaryOriginal

Summary

Eighteen-year-olds cannot be subject to mandatory life without parole sentences under the Eighth Amendment because research shows that they possess the same developmental characteristics as youth under 18.

2020 | Federal Juristiction

Brief of Amicus Curiae Juvenile Law Center in Support of Petitioner-Appellee Luis Noel Cruz and Affirmance

Keywords neurodevelopmental growth; young adults; 18-year-olds; developmental characteristics; mandatory sentences; LWOP; mandatory life without parole; Eighth Amendment (U.S.)
Cruz v. US

Summary of Argument

In Miller v. Alabama, the United States Supreme Court ruled mandatory life without parole sentences unconstitutional for individuals who were juveniles at the time of their offenses. 567 U.S. 460, 465 (2012). The Court, relying on the same underlying scientific research used to bar the death penalty for juveniles, held that children were less culpable than their adult counterparts because of their immaturity, impetuosity, susceptibility to peer influence, and greater capacity for rehabilitation. Id. Further research now indicates that individuals retain these characteristics beyond age 18. Because young adults possess the same adolescent characteristics that the Supreme Court has determined reduce culpability, mandatory life without parole sentences for this population are also disproportionate under the Eighth Amendment. Further, in recognition of the current developmental research, jurisdictions around the country are increasingly raising the age of adulthood above age 18 in situations that implicate the developmental characteristics relied upon in Miller, reinforcing that one’s 18th birthday is an arbitrary and outdated basis upon which to define the constitutional parameters of our sentencing practices. Indeed, as courts around the country have considered age and its attendant characteristics in sentencing older adolescents and young adults, they have consistently found them less deserving of the harshest available penalties—as the District Court did here. This Court should therefore affirm the lower court’s ruling, as Mr. Cruz is developmentally indistinguishable from a defendant under age 18 and cannot constitutionally be sentenced to mandatory life without parole under Miller.

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Summary of Argument

In its landmark decision in Miller v. Alabama (2012), the United States Supreme Court declared mandatory life sentences without the possibility of parole to be unconstitutional for juvenile offenders. The Court's rationale rested on scientific evidence demonstrating the diminished culpability of juveniles due to their developmental immaturity, impulsivity, vulnerability to external influences, and potential for rehabilitation.

Subsequent research has revealed that the neurobiological and psychological traits underpinning reduced culpability in juveniles persist into young adulthood. Therefore, it is argued that mandatory life without parole sentences are similarly disproportionate and violate the Eighth Amendment's prohibition against cruel and unusual punishment for individuals in this age group.

Notably, numerous jurisdictions have recognized the implications of developmental research by raising the age of adulthood in contexts where the factors considered in Miller are relevant. This trend underscores the inadequacy of the arbitrary age of 18 as a threshold for determining the applicability of constitutional sentencing protections.

Courts faced with sentencing older adolescents and young adults have consistently recognized their diminished deservingness of severe punishments, as exemplified by the District Court's ruling in this case. Consequently, it is argued that the lower court's decision should be affirmed because the defendant, Mr. Cruz, exhibits developmental characteristics indistinguishable from those of juveniles and therefore should not be subject to a mandatory life sentence without parole under the principles established in Miller.

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Summary of Argument

In the landmark case of Miller v. Alabama, the Supreme Court ruled that it was unconstitutional to sentence juveniles (those under 18) to life in prison without the possibility of parole. The Court based its decision on scientific evidence that showed juveniles are less mature, more impulsive, and have a greater capacity for rehabilitation than adults.

Recent research suggests that these same characteristics extend beyond the age of 18. Young adults, like juveniles, still have developing brains and are more likely to act on impulse or be influenced by peers. They also have a greater potential for rehabilitation.

Based on this new understanding, many states are raising the age of adulthood in certain situations, acknowledging that the 18th birthday is not a hard and fast line when it comes to maturity and culpability. In fact, courts have often recognized that young adults deserve less severe punishments than older adults.

Therefore, it follows that mandatory life without parole sentences for young adults are also unconstitutional under the reasoning of Miller v. Alabama. These individuals are developmentally similar to juveniles and should not be subject to the harshest possible punishment. The lower court's ruling in this case, which recognizes this principle, should be upheld.

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Summary of Argument

In a big court case called Miller v. Alabama, the highest court in the US said that kids who commit crimes shouldn't automatically get life in prison without the possibility of getting out. The court said that kids are different from adults because they're not as grown up, they make decisions too quickly, they're easily influenced by friends, and they have a better chance of changing for the better.

Now, scientists have found out that young adults, like those just over 18, still have these same qualities. So, it doesn't make sense to give them the same harsh punishment as adults. After all, if kids shouldn't get automatic life sentences, why should young adults?

Other places in the country are starting to realize this too. They're changing the rules so that young adults are treated more like kids when it comes to crime and punishment. This shows that using someone's 18th birthday to decide if they should get life in prison is old-fashioned and unfair.

There's a case where a court decided that a young adult named Mr. Cruz was too similar to a kid to deserve the harshest punishment of life without parole. This means that the court should agree with the lower court's decision because Mr. Cruz is not that different from a kid and shouldn't get the same punishment as an adult.

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Summary of Argument

The Supreme Court decided that it's not fair to make kids who do bad things spend their whole lives in jail without a chance to get out. They said that kids aren't as responsible for their actions as adults because they're not as mature, they make decisions quickly without thinking, they listen to their friends too much, and they can change and become better people.

Now, scientists have found out that young adults, who are over 18, are still a lot like kids in these ways. So, it's not fair to make them spend their whole lives in jail without a chance to get out either.

Many states are starting to understand this, and they're changing their laws to treat young adults differently. They know that it's not right to punish people who are still developing as if they're fully grown adults.

There was a case where a young man named Mr. Cruz did something wrong, and the court decided that he didn't deserve to spend his whole life in jail because he was still young and could change. We should agree with the court's decision because Mr. Cruz is not so different from a kid, and he shouldn't be punished in the same way as an adult.

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Footnotes and Citation

Cite

Brief of Amicus Curiae Juvenile Law Center in Support of Petitioner-Appellee Luis Noel Cruz and Affirmance, Cruz v. United States, No. 19-989 (2d Cir. Feb. 6, 2020).

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