Brief of Juvenile Law Center and National Juvenile Defender Center as Amici Curiae in Support of the Defendant-Appellant
Marsha L. Levick
SummaryOriginal

Summary

Courts must consider a defendant’s age when deciding whether the defendant would have been able to resist coercion and withstand duress because age matters categorically to the determination of culpability.

2007 | State Juristiction

Brief of Juvenile Law Center and National Juvenile Defender Center as Amici Curiae in Support of the Defendant-Appellant

Keywords adolescent vulnerability; decision-making age; duress defense; peer pressure; coercive situations; jury instructions; adolescent development
Screenshot 2024-05-27 at 8.32.33 PM

Summary of Argument

This case calls upon the Court to clarify the role of age in the duress defense. The jury repeatedly asked the trial court for direction as to whether it should consider Gabriel Heinemann’s age in determining whether he acted under duress. The lower court misread state law when it instructed the jury that age mattered to the duress defense only in relative terms - that is, only to the extent that the coercers were older than the coerced. Connecticut law does establish the relevance of age to the duress defense; nowhere does the law suggest that age should be considered only in relative terms.

Both constitutional law and adolescent development research make clear that age matters categorically to the determination of culpability. Adolescents differ from adults cognitively, emotionally, and neurologically. Indeed, the area of the brain tied to risk assessment and self-regulation continues to develop throughout adolescence.

At the time of the incidents in question, defendant Gabriel Heinemann was just 16 years old. Connecticut law, federal Constitutional law and adolescent development research all dictate that the jury should have been instructed to consider his young age - regardless of the age of his coercers - in determining whether he was under duress.

Open Amicus Brief as PDF

Summary of Argument

The present case underscores the need for clarification regarding the significance of age in the duress defense. Connecticut law recognizes the relevance of age in this context, contrary to the trial court's erroneous interpretation that it is pertinent only relative to the ages of the coercers and coerced.

Constitutional law and research in adolescent development converge in acknowledging the categorical importance of age in assessing culpability. Adolescents exhibit distinct cognitive, emotional, and neurological characteristics compared to adults. Specifically, the brain region associated with risk assessment and self-regulation undergoes protracted development throughout adolescence.

In this case, the defendant, Gabriel Heinemann, was a mere 16 years old when the alleged coercion occurred. Connecticut law, along with federal Constitutional law and adolescent development research, mandates that the jury consider his tender age, irrespective of the ages of his coercers, when determining the presence of duress.

Open Amicus Brief as PDF

Summary of Argument

In the case of Gabriel Heinemann, the court was asked to determine if age should be considered when evaluating a claim of duress. The trial court initially stated that age only mattered if the people forcing Heinemann were older than him. However, this interpretation of Connecticut law is incorrect.

State law does recognize that age is relevant to duress claims, and it does not limit this consideration to the relative ages of those involved. In fact, both the Constitution and research on adolescent brain development show that age is a crucial factor in assessing culpability.

Adolescents differ from adults in their cognitive abilities, emotional maturity, and brain development. The part of the brain responsible for evaluating risks and controlling impulses is still developing during adolescence.

Heinemann was only 16 years old when the alleged duress occurred. Under Connecticut law, the Constitution, and adolescent development research, the jury should have been instructed to consider his young age, regardless of the age of those who allegedly coerced him. This would have allowed them to determine if his youth impacted his ability to resist the pressure he faced.

Open Amicus Brief as PDF

Summary of Argument

When someone claims they were forced to do something wrong, the court has to decide if that's true. They use a defense called "duress." The court in this case didn't tell the jury something important: the age of the person matters.

Gabriel Heinemann was only 16 when he was accused of doing something wrong. The jury asked if they should think about his age, but the court said it only mattered if the people who forced him were older. That's not what the law says. The law says age matters on its own.

Why? Because teenagers are different from adults. Their brains are still growing, especially the part that helps them think about risks and control their actions.

So, the jury should have been told to think about Gabriel's age, no matter how old the people were who supposedly forced him. The law, science, and fairness all say so.

Open Amicus Brief as PDF

Summary of Argument

This case is about a teenager named Gabriel Heinemann who said he was forced by other people to commit a crime, but the judge told the jury that Gabriel's age only mattered if the people who forced him were older.

But there's a rule in Connecticut that says age does matter when teens are forced to do things. And even our Constitution says that teens are different from adults.

You see, teens' brains are still growing, especially the part that helps them think about risks and control their actions.

Gabriel was only 16 when he made this mistake. The law and science say that the jury should have thought about his young age, even if the people who forced him weren't older than him.

Open Amicus Brief as PDF

Footnotes and Citation

Cite

Brief of Juvenile Law Center and National Juvenile Defender Center as Amici Curiae in Support of the Defendant-Appellant, State v. Heinemann, S.C. 17789 (Conn. Feb. 8, 2007).

    Highlights