Brief of Amicus Curiae Robert Earl Hawkins in Support of John Antonio Poole
Robert Earl Hawkins
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Summary

The U.S. Supreme Court’s decisions in Miller and Montgomery should be applied to defendants who are over 17 at the time they committed their crime and who were convicted of murder and sentenced to mandatory life without parole.

2021

Brief of Amicus Curiae Robert Earl Hawkins in Support of John Antonio Poole

Keywords prefrontal cortex; LWOP; Miller; Montgomery; hallmark features of youth; neurobiological research; lesser blameworthiness; ages 18-25; young adult; emerging adults; impulsivity; murder
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Summary of Argument

In Miller v. Alabama, The United States Supreme Court ruled that mandatory life without parole sentences are unconstitutional for individuals who were juveniles at the time of their offenses under the Eighth Amendment's prohibit on cruel and unusual punishment. 567 US 460, 465; 132 S Ct 2455; 183 L Ed 2d 497 (2012). The Court, relying on the same underlying scientific research used to bar the death penalty for juveniles, held that children are less culpable than their adult counterparts because of their immaturity, impetuosity, susceptibility to peer influence, and greater capacity for change. Id. Further research now indicates that young people retain their characteristics beyond age 18. Because young adults possess the same adolescent characteristic that the Supreme Court has determined reduce criminal culpability, mandatory life without parole sentences for this population are also disproportionate under both Eighth Amendment and Article 1, sec 16 of the Michigan Constitution. This Court should therefore grant Mr. Poole's application for leave to appeals and extend Miller and Montgomery's protections to defendants who were under 21-year-old at the time of the offense was committed.

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Summary of Argument

In Miller v. Alabama (2012), the Supreme Court of the United States held that mandatory life sentences without parole for juvenile offenders violate the Eighth Amendment's prohibition against cruel and unusual punishment. The Court's decision was based on scientific evidence demonstrating that juveniles possess diminished culpability due to their developmental immaturity, impulsivity, vulnerability to peer pressure, and potential for rehabilitation.

Subsequent research suggests that these characteristics persist beyond the age of 18. Therefore, it is argued that mandatory life without parole sentences are also disproportionate for young adults under the Eighth Amendment and Article 1, sec 16 of the Michigan Constitution. This extension of Miller and Montgomery protections to individuals under 21 at the time of their offenses is warranted based on the shared adolescent characteristics that mitigate criminal culpability.

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Summary of Argument

In the landmark case of Miller v. Alabama, the Supreme Court ruled that it is unconstitutional to sentence juveniles (those under 18) to life in prison without the possibility of parole. The Court's decision was based on scientific evidence showing that juveniles are different from adults in important ways:

  • They are less mature and impulsive.

  • They are more likely to be influenced by their peers.

  • They have a greater potential for rehabilitation.

Recent research suggests that these same characteristics extend to young adults up to age 21. Therefore, it is argued that mandatory life without parole sentences are also cruel and unusual punishment for this population.

Key Points:

  • Juveniles are less responsible for their actions than adults due to their immaturity and other factors.

  • The Supreme Court has ruled that mandatory life without parole sentences for juveniles are unconstitutional.

  • New research indicates that young adults (under 21) share similar characteristics with juveniles that reduce their culpability.

  • It is therefore appropriate to extend the protections of the Miller decision to defendants who were under 21 at the time of their offense.

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Summary of Argument

In a big case called Miller v. Alabama, the highest court in the US said that it's not fair to automatically sentence kids to life in prison without the chance of getting out. Why? Because science shows that kids are different from adults:

  • They're not as mature.

  • They make rash decisions.

  • They're easily influenced by friends.

  • They have a better chance of changing for the better.

Now, new research shows that young adults, even those over 18, still have these same traits. So, some people believe that they should also be protected from automatic life sentences.

They argue that it's not fair to punish young adults as harshly as adults because they're not as responsible for their actions. They also say that giving them a chance at a second chance is better for society in the long run.

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Should Young Adults Get Life in Prison Without Parole?

The Supreme Court in the United States said that it's not fair to give kids who commit crimes life in prison without the chance to get out. They said that kids are different from adults because:

  • They don't think things through as well.

  • They act without thinking.

  • They listen to their friends too much.

  • They can change and become better people.

Now, scientists have found out that young adults, who are older than kids but younger than grown-ups, are still a lot like kids in these ways. So, some people think that young adults shouldn't get life in prison without parole either.

There's a man named Mr. Poole who wants the court to change the rule so that people who were under 21 when they committed a crime can't get life in prison without parole. He thinks it's not fair to treat young adults the same as older adults when it comes to punishment.

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Footnotes and Citation

Cite

Brief of Amicus Curiae Robert Earl Hawkins in Support of John Antonio Poole, People v. Poole, No. 161529 (Mich. 2021).

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