Summary of Argument

This Court's precedent is clear that children may be sentenced to die in prison only if they are among the "rarest of juvenile offenders" "whose crimes reflect permanent incorrigibility." In this case, the Mississippi Supreme Court failed to adhere to this precedent. It held that a judge need not make an incorrigibility finding before sentencing a defendant to life without parole for a crime he committed as a child and need not consider evidence of his capacity for rehabilitation. Without requiring such a finding, there is a real risk judges will sentence youth to spend their lives behind bars arbitrarily. With this arbitrariness comes another risk: the likelihood of judges disproportionately imposing life without parole sentences against African American youth.

The facts of this case highlight these risks and make it an ideal vehicle for this Court to address the proper application of Miller v. Alabama and Montgomery u. Louisiana. Joey Chandler, who is Black, was sentenced to life without the possibility of parole for a murder that he committed when he was seventeen years old. Mr. Chandler's crime undoubtedly warranted a serious sentence, but nothing about the circumstances of his crime suggested permanent incorrigibility. Indeed, over the next ten-plus years in prison, Mr. Chandler proved his capacity for rehabilitation by taking advantage of educational and rehabilitative programs in prison, building a strong relationship with his son and family, and maintaining a nearly spotless record. Yet, at a post-Miller resentencing, a trial judge again sentenced Mr. Chandler to life without parole. The judge did so without addressing whether Mr. Chandler's crime reflected "permanent incorrigibility" and without meaningfully reviewing the relevant factors this Court established in Miller or considering the evidence of Mr. Chandler's rehabilitation.

The Court should grant certiorari and hold that a judge must find permanent incorrigibility before sentencing a child to life without parole. The Court should do so to: (1) ensure juvenile life without parole sentences remain the rare exception and not the rule; (2) protect against racial biases affecting sentencing decisions; (3) guarantee meaningful appellate review; and (4) maintain the public's faith in the judiciary and norms of procedural justice. Consistent with Miller and Montgomery, this Court should ensure that judges consider the relevant factors before sentencing children to life without parole, especially the child's ability to live a productive adult life.

Summary of Argument

The case of Joey Chandler v. Mississippi presents a compelling opportunity for the Supreme Court to reexamine the application of its precedent regarding life without parole sentences for juvenile offenders. This case highlights the potential for arbitrary and racially biased sentencing practices when courts fail to adhere to the established standard requiring a finding of "permanent incorrigibility" before imposing such a sentence.

The Court's prior rulings in Miller v. Alabama and Montgomery v. Louisiana established that life without parole sentences for juvenile offenders should be reserved for the "rarest of juvenile offenders" whose crimes demonstrate "permanent incorrigibility." However, the Mississippi Supreme Court's decision in Chandler deviated from this precedent by ruling that such a finding is not necessary. This failure to require an incorrigibility finding creates a significant risk of arbitrary sentencing, particularly for African American youth.

The facts of Chandler exemplify these risks. Joey Chandler, a Black individual, was sentenced to life without parole for a murder committed at the age of seventeen. While his crime warranted a severe sentence, there was no evidence of permanent incorrigibility. In fact, over the following decade, Mr. Chandler demonstrated his capacity for rehabilitation through participation in educational and rehabilitative programs, fostering a strong relationship with his family and son, and maintaining an exemplary prison record. Nevertheless, at a resentencing following Miller, the trial judge again imposed life without parole without addressing the issue of incorrigibility, adequately considering the Miller factors, or acknowledging Mr. Chandler's rehabilitation efforts.

The Court's granting of certiorari in Chandler would allow it to address the proper application of Miller and Montgomery and ensure that:

• Juvenile life without parole remains the exception, not the rule: Requiring an incorrigibility finding ensures that these sentences are reserved for truly exceptional cases.

• Racial biases in sentencing are mitigated: The risk of disproportionate sentencing against African American youth is reduced by requiring judges to consider evidence of rehabilitation and permanent incorrigibility.

• Meaningful appellate review is guaranteed: The requirement of a specific finding allows for more thorough appellate review of sentencing decisions.

• Public confidence in the judiciary is maintained: Ensuring fair and consistent application of the law enhances the public's trust in the judicial system.

By upholding the Miller and Montgomery standards, the Court should require judges to consider relevant factors, including the juvenile offender's capacity for rehabilitation, before imposing life without parole sentences. This would ensure that these sentences are reserved for truly incorrigible offenders and protect against arbitrary and potentially racially biased sentencing practices.

Summary of Argument

This case presents an opportunity for the Court to reassert its precedent on juvenile sentencing. The Court has consistently held that life without parole sentences for juveniles should only be imposed in the rarest of cases, where the crime reflects "permanent incorrigibility." However, the Mississippi Supreme Court has departed from this precedent, holding that a finding of incorrigibility is not necessary before imposing such a sentence. This failure to require a finding of incorrigibility risks arbitrary sentencing and disproportionate impact on African American youth.

The case of Joey Chandler, a Black man sentenced to life without parole for a murder he committed at age seventeen, exemplifies these risks. While Mr. Chandler's crime warranted a serious sentence, there was no evidence to suggest permanent incorrigibility. Indeed, over the following decade in prison, Mr. Chandler demonstrated his capacity for rehabilitation through participation in educational and rehabilitative programs, maintaining a strong relationship with his family, and exhibiting exemplary behavior. Yet, despite this evidence, a trial judge again sentenced Mr. Chandler to life without parole without considering his capacity for rehabilitation or the relevant factors established by the Court in Miller v. Alabama and Montgomery v. Louisiana.

The Court should grant certiorari and reaffirm the requirement of a finding of permanent incorrigibility before sentencing a child to life without parole. This would ensure that such sentences remain rare, protect against racial bias in sentencing, guarantee meaningful appellate review, and maintain public trust in the judiciary and procedural justice. The Court should ensure that judges comprehensively consider relevant factors, including the child's potential for a productive adult life, before imposing such a severe sentence.

Summary of Argument

The Supreme Court has ruled that children can only be sentenced to life in prison without the possibility of parole if they are extremely dangerous and unlikely to ever change their behavior. In this case, a Mississippi court ignored this rule. They let a judge sentence a young man named Joey Chandler to life in prison without considering whether he would always be a danger to society.

Joey committed a serious crime when he was 17, but there was no evidence he would always be a criminal. In fact, he has shown signs of change while in prison. He has taken classes, built strong relationships with his family, and behaved well. But the judge didn’t consider any of this and sentenced him to life in prison again.

The Supreme Court should review this case. They need to make sure judges follow the law and consider whether a young person is likely to be a danger forever before sending them to prison for life. This will help prevent unfair sentences, especially for Black youth who are often treated unfairly by the justice system.

Summary of Argument

The case is about a young man named Joey Chandler who was sentenced to life in prison without the chance of getting out. This happened because he committed a crime when he was 17 years old. Joey is Black, and the Court believes there's a risk that judges might give this type of sentence more often to Black kids.

Joey's crime was serious, but there's no proof he'll always be a bad person. In fact, he's shown he can change while in prison. He learned new things, got close to his family, and stayed out of trouble. But the judge didn't look at all this when giving him life in prison without the chance of parole.

The Court wants to make sure that judges only give this harsh sentence to kids who are truly a danger to society. They want to stop judges from being unfair and to make sure the court system is fair for everyone. They also want to make sure that judges look at all the facts before giving a kid life in prison.