Summary of Argument

The United States Supreme Court has held unequivocally that "youth matters," and that children are categorically different from adults for purposes of criminal sentencing. For this reason, before condemning a child to die in prison by imposing a sentence of life without the possibility of parole, a court is required by the Eighth Amendment to the United States Constitution to consider the child's youth and attendant circumstances as mitigating factors. Miller v. Alabama, 132 S. Ct. 2455 (2012).

Eric Long did not receive that constitutionally mandated treatment. Nothing in the record indicates that the trial judge - who sentenced Eric before Miller was decided, and thus did not have the benefit of the Supreme Court's latest pronouncements regarding the constitutional significance of his youth - considered his age at all. For this reason alone, Eric's sentence should be invalidated.

Moreover, this Court has previously held that Article I, Section 9 of the Ohio Constitution provides unique and independent protection against cruel and unusual punishments, and that children are categorically less culpable than adults. Amicus curiae NACDL urges this Court to vindicate those principles by holding that the Ohio Constitution categorically prohibits imposition of a life without parole sentence on any juvenile offender.

Summary of Argument

The United States Supreme Court has established a precedent recognizing the distinct developmental characteristics of youth, deeming them categorically different from adults in the context of criminal sentencing. This distinction is enshrined in the Eighth Amendment of the United States Constitution, mandating the consideration of mitigating factors related to a child's age and circumstances before imposing a sentence of life without the possibility of parole.

The case of Eric Long presents a clear violation of this constitutional mandate. The trial judge, sentencing Eric prior to the Supreme Court's ruling in Miller v. Alabama, failed to consider Eric's age as a mitigating factor. This oversight, coupled with the lack of evidence indicating the judge's consideration of Eric's youth, necessitates the invalidation of his sentence.

Summary of Argument

The United States Supreme Court has established that youth is a significant factor in criminal sentencing, distinguishing children from adults. This principle, rooted in the Eighth Amendment, requires courts to consider a child's age and circumstances as mitigating factors before imposing a life sentence without the possibility of parole.

The case of Eric Long presents a clear violation of this constitutional mandate. The trial judge, who sentenced Eric prior to the Supreme Court's ruling in Miller v. Alabama, failed to consider Eric's age as a mitigating factor. Consequently, Eric's sentence should be overturned.

Summary of Argument

The Supreme Court has ruled that children are different from adults when it comes to criminal sentencing. This means that before a child can be sentenced to life in prison without the possibility of parole, a judge must consider the child's age and circumstances. In Eric Long's case, the judge did not consider his age when sentencing him. Therefore, Eric's sentence should be overturned.

Summary of Argument

Eric Long was sentenced to life in prison without the possibility of parole. The Supreme Court says that when a child is sentenced to prison, a judge must consider how young they are. This is because children are different from adults, and they may change and learn as they grow up. In Eric's case, the judge did not consider his age. So, Eric's sentence should be changed.