Summary of Argument

Amici Curiae ask this Court to grant certiorari to clarify that juvenile adjudications should not be used to enhance subsequent adult criminal sentences under Apprendi v. New Jersey, 530 U.S. 466 (2000).

This rule is proper for two reasons. First, as Judge Posner recognized in his dissenting opinion below, adjudications obtained in the juvenile court system as currently fashioned “may well lack the reliability of real convictions in criminal courts.” Welch v. United States, 604 F.3d 408, 432 (7th Cir. 2010) (Posner, J., dissenting). This systemic risk of unreli- ability is a result of several factors, including the ab- sence of jury trials; a juvenile court culture that dis- courages and sometimes precludes zealous and ad- versarial advocacy; and a heightened possibility that some of the evidence introduced in juvenile court, such as juvenile confessions, may be unreliable. Against such a backdrop, it would be fundamentally unfair to allow the use of juvenile adjudications to enhance adult sentences.

Second, the rule is consistent with this Court’s longstanding recognition of the differences between adults and juveniles. Through more than six decades of jurisprudence, this Court has recognized that youth are different from adults; they are less mature, more vulnerable to external pressure, and more capable of redemption and growth. The juvenile justice system has historically functioned with these differences in mind. Quoting Judge Posner below, “[t]he constitutional protections to which juveniles have been held to be entitled have been designed with a different set of objectives in mind than just recidivist enhancement.” Id. at 431. The use of juvenile adju- dications to enhance adult sentences years later runs fundamentally contrary to the notion of a separate, protective juvenile court system.

Summary of Argument

Amici Curiae request the Supreme Court to grant certiorari and clarify that juvenile adjudications should not be used to enhance subsequent adult criminal sentences based on the precedent established by Apprendi v. New Jersey, 530 U.S. 466 (2000).

This position is justified for two primary reasons. Firstly, as noted by Judge Posner in his dissenting opinion, the current juvenile court system's inherent structure raises concerns about the reliability of juvenile adjudications, potentially rendering them less credible than convictions obtained in criminal courts. This inherent unreliability stems from several factors: the absence of jury trials; a juvenile court culture that discourages and occasionally prevents vigorous and adversarial legal representation; and the heightened risk of unreliable evidence being presented, such as juvenile confessions. Consequently, it would be inherently unfair to permit the use of juvenile adjudications as a basis for increasing adult sentences.

Secondly, this rule aligns with the Supreme Court's consistent recognition of the fundamental distinctions between adults and juveniles. Over six decades of legal precedent underscores the recognition that juveniles, due to their immaturity, vulnerability to external influences, and greater capacity for redemption and growth, differ significantly from adults. The juvenile justice system has historically operated with these distinctions as a guiding principle. As Judge Posner aptly stated, "the constitutional protections to which juveniles have been held to be entitled have been designed with a different set of objectives in mind than just recidivist enhancement." The practice of employing juvenile adjudications to enhance adult sentences years later fundamentally contradicts the principles underlying the existence of a separate, protective juvenile court system.

Summary of Argument

Amici Curiae argue that the Supreme Court should review a case to clarify that juvenile adjudications shouldn't be used to increase adult criminal sentences, citing the precedent set by Apprendi v. New Jersey.

This argument rests on two core principles:

1. Reliability Concerns: Juvenile court proceedings, as they are currently structured, may lack the same level of reliability as adult criminal trials. This is due to factors such as the absence of jury trials, a less adversarial approach in juvenile courts, and potential unreliability of evidence like juvenile confessions. Using these adjudications to enhance adult sentences would be unfair given their inherent potential for unreliability.

2. Fundamental Differences Between Adults and Juveniles: The Supreme Court has consistently recognized that juveniles are distinct from adults. They are less mature, more susceptible to external influence, and possess greater potential for growth and rehabilitation. The juvenile justice system has historically acknowledged these differences. Using juvenile adjudications to enhance adult sentences years later contradicts the purpose of a separate, protective juvenile justice system.

Summary of Argument

The Amici Curiae are asking the Supreme Court to clarify the use of past juvenile records in adult criminal sentencing. They argue that using juvenile adjudications to increase adult sentences is wrong for two reasons.

First, juvenile adjudications often lack the reliability of adult criminal convictions. This is because juvenile courts are different from adult criminal courts, lacking jury trials, often having less zealous legal representation, and sometimes accepting evidence that may be unreliable, like confessions from young people.

Second, the Supreme Court has recognized that juveniles are different from adults. They are less mature, more susceptible to influence, and more likely to change their behavior. The juvenile justice system aims to address these differences. Using juvenile records to increase adult sentences years later conflicts with the idea of a separate, protective juvenile court system.

Summary of Argument

This brief argues that judges should not look at what happened in juvenile court when they decide how long an adult should go to jail.

There are two main reasons for this. First, the lawyers think that what happens in juvenile court might not always be fair or reliable. This is because kids don't get a jury trial, their lawyers might not fight as hard for them, and the evidence used against them might not be trustworthy.

Second, they think that it's not fair to use what happened in juvenile court to decide how long a grown-up goes to jail because kids are different from adults. The Supreme Court has said that kids are not as mature, they are easily influenced, and they can change and learn from their mistakes. Because of this, there's a special system for kids in trouble that's supposed to help them, and it's not right to use it to punish them later when they are grown up.