Brief of Amicus Curiae on Behalf of Qu’eed Batts
Marsha Levick
Jessica Feierman
Emily Keller
Bradley S. Bridge
Ellen T. Greenlee
SummaryOriginal

Summary

The imposition of a life without parole sentence on a juvenile is barred by the Pennsylvania and United States constitutions and by international law, emphasizing the unconstitutional nature of such sentences.

2010 | State Juristiction

Brief of Amicus Curiae on Behalf of Qu’eed Batts

Keywords juvenile LWOP; juvenile life without parole; international law; cruel and unusual punishment; Eighth Amendment; murder; Graham
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Summary of Argument

Amici submit that a mandatory sentence of life without the possibility of parole for a fourteen-year old youth convicted of first degree homicide violates both the United States and Pennsylvania Constitutions. In Graham v. Florida, the United States Supreme Court held the sentence of life without parole unconstitutional as applied to a juvenile convicted of violating his probation by committing a home invasion robbery, possessing a firearm, and associating with persons engaged in criminal activity. The holding was grounded in developmental and scientific research that demonstrates that juveniles possess a greater capacity for rehabilitation, change and growth than adults. Considering this research in light of the four accepted rationales for the imposition of criminal sanctions – incapacitation, deterrence, retribution and rehabilitation – the Graham Court held that a life without parole sentence served no legitimate penological purpose when applied to juveniles under the age of eighteen. The Graham Court also held that such a sentence was contrary to evolving standards of decency under the Eight Amendment’s cruel and unusual punishments clause, noting that a majority of states prohibited the practice and that, even among those that permitted it, the sentence was rarely imposed.

Graham applies to the sentence challenged here. A life without parole sentence for a juvenile lacks empirical justification in light of the distinctive developmental characteristics of juvenile offenders, and therefore serves none of the traditional justifications for punishment. Striking this punishment is also consistent with longstanding specialized treatment of juveniles under the Constitution.

Moreover, Pennsylvania’s sentencing structure is starkly out of touch with national trends; only three other states nationwide mandate a sentence of life without parole for youth fourteen years old or younger convicted of homicide. Indeed, the constitutional problems with life without parole sentences are heightened in Pennsylvania by the mandatory nature of the life imprisonment without parole sentencing scheme. The sentencing scheme not only fails to address the reduced culpability of adolescents, it actually precludes the judge from taking age into account. Graham rejected such categorical judgments about juveniles.

The international consensus against imposition of life without parole sentences upon juveniles further underscores that the sentence is unconstitutional. International law prohibits the imposition of life without parole sentences on juveniles. Finally, the Pennsylvania Constitution, which is broader than the United States Constitution, barring sentences that are “cruel,” rather than only those that are “cruel and unusual,” also bars such sentences.

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Summary of Argument

In Graham v. Florida, the United States Supreme Court declared unconstitutional the imposition of life sentences without parole (LWOP) on juveniles convicted of non-homicide offenses. This decision was based on scientific evidence demonstrating the unique developmental characteristics of juveniles and the diminished penological justifications for such severe sentences. This analysis examines the constitutionality of mandatory LWOP sentences for 14-year-old youths convicted of first-degree homicide under both the United States and Pennsylvania Constitutions.

Graham v. Florida and Juvenile Sentencing

The Graham Court held that LWOP sentences for juveniles violate the Eighth Amendment's prohibition against cruel and unusual punishment. The Court recognized that juveniles possess a greater capacity for rehabilitation and change than adults, and that LWOP sentences fail to serve any legitimate penological purpose, such as incapacitation, deterrence, retribution, or rehabilitation. Additionally, the Court noted the evolving standards of decency, reflected in the majority of states prohibiting LWOP for juveniles and its rare imposition even in states that permit it.

Application of Graham to Mandatory LWOP Sentences

The principles articulated in Graham apply equally to mandatory LWOP sentences for juveniles convicted of homicide. Such sentences fail to account for the distinctive developmental characteristics of juvenile offenders and the reduced culpability associated with their actions. Moreover, they preclude individualized sentencing considerations, such as the offender's age and potential for rehabilitation.

Pennsylvania's Sentencing Scheme and National Trends

Pennsylvania's mandatory LWOP sentencing scheme for juveniles is an outlier compared to national trends. Only three other states impose such sentences for youths as young as 14. The mandatory nature of Pennsylvania's scheme exacerbates the constitutional concerns raised by LWOP sentences, as it prevents judges from considering the mitigating factor of age.

International Consensus and the Pennsylvania Constitution

International law prohibits the imposition of LWOP sentences on juveniles, further underscoring the unconstitutionality of such sentences. Additionally, the Pennsylvania Constitution's prohibition against "cruel" punishments, which is broader than the Eighth Amendment's "cruel and unusual" standard, provides further support for barring LWOP sentences for juveniles.

Conclusion

Mandatory LWOP sentences for 14-year-old youths convicted of first-degree homicide violate both the United States and Pennsylvania Constitutions. These sentences are not supported by empirical evidence, fail to serve legitimate penological justifications, and contravene evolving standards of decency and international norms. The Pennsylvania Constitution's broader protection against cruel punishments further strengthens the argument against such sentences.

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Summary of Argument

Sentencing a 14-year-old to life in prison without the possibility of parole for first-degree homicide raises constitutional concerns.

In the landmark case of Graham v. Florida, the Supreme Court ruled that life sentences without parole for juveniles convicted of non-homicide offenses violate the Eighth Amendment's prohibition against cruel and unusual punishment. The Court based its decision on scientific evidence showing that juveniles have a greater capacity for rehabilitation than adults.

Life without parole sentences for juveniles fail to serve any legitimate penological purpose, such as:

  • Incapacitation: Juveniles pose a lower risk of reoffending than adults.

  • Deterrence: Such harsh sentences do not deter juvenile crime.

  • Retribution: Juveniles have a diminished culpability due to their developmental immaturity.

  • Rehabilitation: Life without parole sentences deny juveniles the opportunity for growth and change.

Most states prohibit life without parole sentences for juveniles, and even in states where it is allowed, it is rarely imposed. This reflects an evolving societal consensus against such extreme punishments for young offenders.

Pennsylvania is an outlier with its mandatory life without parole sentence for juveniles convicted of homicide. This scheme fails to consider the unique characteristics of juvenile offenders and prevents judges from taking age into account.

International law prohibits life without parole sentences for juveniles, highlighting the unconstitutionality of such punishments.

The Pennsylvania Constitution's broader prohibition against "cruel" punishments further supports the unconstitutionality of life without parole sentences for juveniles.

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Summary of Argument

Should 14-year-olds who commit murder be sentenced to life in prison without the chance of parole (getting out)? The Supreme Court said "no" in a case called Graham v. Florida.

Why Did the Court Say No?

  • Teens are still developing and have a better chance of changing and becoming better people than adults.

  • Life sentences without parole don't help with rehabilitation, which is one of the main reasons for punishment.

  • Most states don't allow this sentence for teens, and it's rarely used even in states that do.

What Does This Mean for Pennsylvania?

Pennsylvania is one of only three states that automatically sentences 14-year-olds convicted of murder to life without parole. This is out of step with the rest of the country.

  • The law doesn't consider that teens are less responsible for their actions than adults.

  • Judges can't even take the teen's age into account when sentencing.

International Perspective

Other countries around the world don't allow life sentences without parole for teens.

Pennsylvania's Constitution

Pennsylvania's Constitution says that punishments can't be "cruel." Life sentences without parole for teens are considered cruel.

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Summary of Argument

Some people think that kids who are 14 years old and commit a serious crime should be locked up for the rest of their lives without any chance of getting out. But the Supreme Court says that's not fair.

Why? Because kids are different from adults. Their brains are still growing and changing, and they can learn from their mistakes and become better people.

When we punish people, we want to:

  • Keep them from hurting others

  • Scare others from doing bad things

  • Make the person pay for what they did

  • Help them change and become better

But locking a kid up for life doesn't do any of those things. It doesn's keep them from hurting others, because they're in jail. It doesn't scare others, because most kids don't think they'll get caught. It doesn't make the person pay for what they did, because they'll never get out of jail. And it doesn't help them change, because they'll never have a chance to learn and grow.

Most states don't allow kids to get life in jail without parole. And even in the states that do, it's very rare.

Pennsylvania is one of only three states that says kids as young as 14 must get life in jail without parole if they commit a serious crime. This is wrong because it doesn't take into account that kids are different from adults.

Other countries around the world also think it's wrong to lock kids up for life without parole. And the Pennsylvania Constitution says that punishments can't be cruel. Locking a kid up for life without parole is cruel.

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Footnotes and Citation

Cite

Brief of Amicus Curiae on Behalf of Qu'eed Batts, Commonwealth v. Batts, 79 MAP 2009 (Pa. 2009).

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