Summary of Argument

This case concerns the scope of the constitutional rule announced in Miller v. Alabama, 567 U.S. 460 (2012), and declared retroactive in Montgomery v. Louisiana, 136 S. Ct. 718 (2016). Miller established a substantive rule that renders life without parole disproportionate for the vast majority of juveniles in light of their “diminished culpability and heightened capacity for change.” Id. at 479. Under Miller, only those juveniles who are permanently incorrigible are constitutionally eligible for life without parole.

Petitioner Brett Jones, who was sentenced to life without parole for crimes committed as a juvenile, maintains that his sentence should be vacated because the sentencing court failed to find him permanently incorrigible.

To conform to Miller, a sentencing scheme must require the sentencing authority to separate juveniles who cannot be subjected to life without parole (juveniles whose crimes reflect “transient immaturity”) from the rare juveniles who can (those whose crimes reflect “irreparable corruption”). Miller, 567 U.S. at 479-80 (quoting Roper v. Simmons, 543 U.S. 551, 573 (2005)). A life-without-parole sentence is permitted solely when an offender is permanently incorrigible. Otherwise, juvenile offenders are constitutionally immune from receiving that sentence. Id.

Because the sentencing court here made no effort to address and engage with how Jones’s youth made him different than an adult defendant—and how those differences counseled against life without parole—the sentencing scheme fell short of what Miller requires.

Miller, after all, “did more than require a sentencer to consider a juvenile offender’s youth before imposing life without parole; it established that the penological justifications for life without parole collapse in light of ‘the distinctive attributes of youth.’” Montgomery, 136 S. Ct. at 734. To effectuate the substantive guarantee of proportionate punishment, this Court directed lower courts to evaluate if the child at issue is capable of rehabilitation, or is among the rare “permanent[ly] incorrigib[le]” children. Although the Court did not mandate the procedure necessary to ensure that only “permanently incorrigible” children were sentenced to life without parole, it warned that this lack of guidance “should not be construed to demean the substantive character of the federal right at issue.” Id. at 735. On the contrary, the Court made clear that to impose a life without parole sentence on children whose crimes reflect transient immaturity would be a “deprivation of a substantive right.” Id. at 734.

Amici respectfully urge the Court to clarify that a sentencer must engage with youth and its attendant circumstances in order to distinguish between youthful immaturity and irreparable corruption before condemning a juvenile to life in prison, and that evidence of actual rehabilitation militates against a finding that a particular juvenile offender is among the “rarest of children, those whose crimes reflect ‘irreparable corruption.’” Id. at 726. Such a clarification is necessary to ensure implementation of this Court’s substantive rules and uphold the rule of law.

Summary of Argument

This article examines the constitutional implications of Miller v. Alabama (2012) and Montgomery v. Louisiana (2016) regarding the sentencing of juveniles to life without parole (LWOP). Miller established that LWOP is disproportionate for most juveniles due to their reduced culpability and potential for rehabilitation. Only juveniles deemed permanently incorrigible are eligible for LWOP under Miller.

Sentencing Requirements under Miller

To comply with Miller, sentencing courts must distinguish between juveniles whose crimes reflect "transient immaturity" and those rare juveniles who exhibit "irreparable corruption." LWOP is only permissible for the latter group. Sentencing courts must consider the juvenile's youth and its impact on their culpability and potential for change.

The Case of Brett Jones

Petitioner Brett Jones argues that his LWOP sentence violates Miller because the sentencing court failed to find him permanently incorrigible. The court did not adequately consider the mitigating factors associated with his youth.

Amici's Argument

Amici urge the Court to clarify that sentencing courts must explicitly address the juvenile's youth and its implications for rehabilitation. Evidence of actual rehabilitation should weigh against a finding of permanent incorrigibility.

Conclusion

Ensuring that only permanently incorrigible juveniles receive LWOP sentences is crucial for upholding the substantive right to proportionate punishment established in Miller. Sentencing courts must engage with the unique characteristics of youth to make this determination.

Summary of Argument

In the case of Miller v. Alabama, the Supreme Court ruled that it is unconstitutional to sentence most juveniles to life without parole. This is because juveniles are less responsible for their actions and have a greater potential for rehabilitation than adults.

Brett Jones' Case

Brett Jones was sentenced to life without parole for crimes he committed as a juvenile. He argues that his sentence should be overturned because the court did not find him to be "permanently incorrigible." Under Miller, only juveniles who are permanently incorrigible can be sentenced to life without parole.

The Importance of Considering Youth

When sentencing juveniles, courts must consider how their youth affects their culpability and potential for rehabilitation. Juveniles are typically less mature and more impulsive than adults, and they are more likely to change and grow.

Evidence of Rehabilitation

If a juvenile offender has shown evidence of rehabilitation, this should be considered when determining whether they are permanently incorrigible. The Supreme Court has stated that only the "rarest of children" are truly beyond redemption.

Conclusion

Courts must carefully consider the unique characteristics of youth before sentencing juveniles to life without parole. Only those who are truly irredeemable should receive this harsh punishment. Evidence of rehabilitation should be taken into account, as it suggests that the offender is not permanently incorrigible.

Summary of Argument

In the case of Brett Jones, the court is deciding if it's fair to sentence young people to life in prison without the chance of parole (getting out).

What the Law Says

In the past, the Supreme Court ruled that:

• Young people are different from adults because they're not as responsible for their actions and can change for the better.

• Only young people who are truly bad and can't be changed should be sentenced to life without parole.

Brett Jones' Case

Brett Jones was sentenced to life without parole for crimes he committed as a young person. He argues that the court didn't consider his age and the possibility that he could change.

The Argument

Some people believe that:

• Courts should always think about a young person's age before sentencing them to life without parole.

• If a young person has shown that they've changed for the better, they shouldn't be considered "truly bad."

This would make sure that the law is fair and that young people who made mistakes have a chance to turn their lives around.

Summary of Argument

There's a law that says most kids and teens who commit crimes shouldn't be sentenced to life in prison without the chance of getting out. This is because kids are still growing and changing, and they might not be as responsible for their actions as adults.

One kid named Brett Jones was sentenced to life in prison without parole for crimes he did when he was a kid. He says his sentence is unfair because the court didn't think about how being a kid made him different from an adult.

The rule says that only kids who are really, really bad and can't be helped should get life without parole. The court has to decide if a kid is one of those rare cases before giving them that sentence.

Brett's friends are asking the court to make it clear that judges have to think about how being a kid affects a person's actions. They also say that if a kid has shown that they've changed and become a better person, they shouldn't be considered one of those rare, really bad kids.

This is important because it's about making sure that kids are treated fairly and that they have a chance to turn their lives around.