Summary of Argument

First, amicus explains that courts reviewing the constitutionality of a life without parole sentence imposed under a recidivist statutory scheme routinely consider all strikes as part of the current offense. With respect to the constitutional question posed, amicus explains how Mr. Williams’ life without parole sentence runs afoul of the principles on which Graham and Miller were decided. Graham not only barred the imposition of life without parole on juvenile nonhomicide offenders, but also stands for the larger principle that courts must closely scrutinize harsh punishments imposed on juveniles, due to their diminished moral culpability. And Miller prohibits mandatory life with parole sentencing schemes for juvenile homicide offenders, as those schemes deprive courts of the opportunity to consider the mitigating qualities of youth. Together,Graham and Miller lead to the conclusion that a three strikes law that imposes life without parole based, in part, on conduct committed as a juvenile, is unconstitutional.

Second, amicus explains how Mr. Williams’ life without parole sentence is unconstitutional under article I, section 14. This Court adopted a categorical bar on juvenile life without parole in Bassett because traditional proportionality analysis under State v. Fain, 94 Wn.2d 387, 617 P.2d 720 (1980), does not “adequately address the special concerns inherent to juvenile sentencing.” Bassett, 198 Wn. App. ¶ 49. While Mr. Williams was not a juvenile at the time of the third strike, his age at the time of the first strike is material to the larger constitutional inquiry, as those same “special concerns” are at play. The only way to avoid the risk that harsh punishment might be imposed on those whose strike offenses reflect transient immaturity is to adopt a corollary of the categorical bar on juvenile life without parole: that no offense committed as a juvenile can count as a strike.

Summary of Argument

This amicus brief argues that the life without parole sentence imposed on Mr. Williams under a three strikes law is unconstitutional. The brief presents two key arguments:

First, it contends that the sentence violates the principles established in Graham v. Florida and Miller v. Alabama. These cases emphasized the need for courts to carefully consider the diminished moral culpability of juveniles and to avoid imposing mandatory life without parole sentences on them. The brief argues that because Mr. Williams' sentence relies in part on conduct committed as a juvenile, it fails to adequately account for these principles.

Second, the brief argues that the sentence violates Article I, Section 14 of the Washington State Constitution. This section prohibits life without parole sentences for juveniles, a rule established in State v. Bassett. The brief extends this reasoning to argue that offenses committed as a juvenile should not be considered strikes for the purposes of a three strikes law, as this would create a risk of imposing harsh punishments on individuals whose offenses were influenced by transient immaturity.

Summary of Argument

The amicus brief argues that a life without parole sentence imposed under a "three strikes" law is unconstitutional when it is based, in part, on conduct committed as a juvenile. The argument centers on two key points:

First, the brief draws upon the precedent established in Graham and Miller, which both challenge the constitutionality of life without parole sentences for juveniles. Graham prohibits such sentences for non-homicide offenses, while Miller prohibits mandatory life without parole sentences for homicide offenses, recognizing the unique characteristics of youth. The amicus argues that these precedents necessitate a thorough review of the constitutionality of "three strikes" laws, which potentially punish juvenile offenses with life without parole.

Second, the brief contends that imposing life without parole based on a strike offense committed as a juvenile violates Article I, Section 14 of the state constitution. Bassett established a categorical bar on life without parole for juveniles, citing the "special concerns" inherent to juvenile sentencing. The amicus contends that these concerns extend to any strike offense committed as a juvenile, even if the third strike occurred later in adulthood. The brief argues that this is necessary to ensure that individuals are not subjected to severe punishments based on youthful, and potentially transitory, misconduct.

Summary of Argument

The argument presented here focuses on the constitutionality of Mr. Williams' life without parole sentence, arguing that it violates both the principles established by previous court rulings and the state constitution.

Firstly, the argument points out that the court usually considers all strikes, including those committed when the individual was a juvenile, as part of the current offense. This practice contradicts the rulings in Graham and Miller, which emphasize the diminished culpability of juveniles and the need for individualized sentencing. Because Mr. Williams' life without parole sentence is based on a three-strike law that includes a strike committed during his youth, it goes against the principles of these precedents.

Secondly, the argument contends that Mr. Williams' sentence violates Article I, Section 14 of the state constitution. The court has already established a categorical bar on life without parole for juveniles, recognizing that traditional sentencing methods don't adequately address the unique circumstances of youth. While Mr. Williams was not a juvenile during his third strike, his age during the first strike is still relevant because the "special concerns" surrounding juvenile offenders remain applicable. To prevent the possibility of harsh punishments being imposed on individuals whose offenses reflect youthful immaturity, the argument proposes a corollary to the juvenile life without parole bar: no offense committed as a juvenile should count as a strike.

Summary of Argument

This argument is about a man named Mr. Williams who was sentenced to life in prison without the chance of parole. This happened because of a law called the "three strikes law." The law says that if someone commits three serious crimes, they will be sentenced to life without parole. One of Mr. Williams's strikes happened when he was a teenager. This argument says that sentencing someone to life without parole for something they did as a teenager is unfair.

The argument explains that the courts have already ruled that it's wrong to sentence teenagers to life without parole for crimes that aren't murder. The courts say that teenagers are different from adults and don't always understand the consequences of their actions. This argument is saying that the same rule should apply to the "three strikes law." It's unfair to count a crime from someone's childhood as one of the strikes that could lead to a life sentence.