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

Summary

Courts must consider a defendant’s age when deciding whether the defendant would have been able to resist coercion and withstand duress because both constitutional law and adolescent development research make clear that age matters.

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
Amicus Connecticut v Heinemann

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.

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Summary of Argument

The case under consideration highlights the need for legal clarity regarding the impact of age on the defense of duress. The trial court's misinterpretation of Connecticut law, which limited the relevance of age to relative comparisons with the coercers, contradicts established state jurisprudence.

Constitutional law and developmental psychology emphasize the categorical importance of age in assessing culpability. Adolescents exhibit distinct cognitive, emotional, and neurological characteristics compared to adults. The prefrontal cortex, responsible for risk evaluation and self-control, undergoes significant development during adolescence.

In the case of Gabriel Heinemann, a 16-year-old at the time of the alleged duress, Connecticut law, federal constitutional principles, and scientific evidence on adolescent development support the consideration of his age as a standalone factor in the duress analysis, irrespective of the age of his coercers. This consideration is crucial in determining whether his actions were the result of genuine duress or a failure to exercise reasonable resistance.

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Summary of Argument

The case before the court raises the question of how age should be considered when someone claims they acted under duress, meaning they were forced to do something illegal. The jury asked the trial court whether they should take Gabriel Heinemann's age into account. The court responded that age only mattered if the people forcing Heinemann were older than him. However, Connecticut law suggests that age should be considered on its own, not just in comparison to others.

Both the Constitution and research on adolescent brain development support the idea that age is important in determining responsibility for actions. Teenagers have different cognitive, emotional, and brain structures than adults. The part of the brain responsible for assessing risk and controlling impulses is still developing during adolescence.

In this case, Heinemann was only 16 years old when the incident occurred. Connecticut law, the Constitution, and research on adolescent development indicate that the jury should have been instructed to consider his age, regardless of the age of those who forced him into the illegal actions. This consideration would help determine whether he was truly acting under duress.

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Summary of Argument

Imagine you're in a situation where someone older is pressuring you to do something you don't want to do. Should your age be considered when deciding if you were forced into it? That's the question being asked in this case.

A 16-year-old named Gabriel Heinemann was in trouble and the jury kept asking the judge if they should think about his age when deciding if he was forced to do something. But the judge said age only mattered if the people forcing him were older than him. However, the law in Connecticut (where the case took place) doesn't say that.

Studies show that teenagers' brains are still developing, especially the part that helps them make good decisions and control their impulses. That's why it's important to consider age when looking at cases where someone is claiming they were forced to do something.

So, the question is: should Gabriel Heinemann's young age be taken into account when deciding if he was under duress, even if the people forcing him weren't older than him? The answer should be yes, because his brain was still developing and that could have affected his ability to resist pressure.

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Summary of Argument

Gabriel Heinemann was a 16-year-old boy who was in trouble with the law. He was accused of doing something bad, but he said he was forced to do it. The court wanted to know if they should consider Gabriel's age when deciding if he was really forced.

The court said that age only mattered if the people forcing Gabriel were older than him. But the law in Connecticut, the state where Gabriel lived, says that age matters even if the people forcing him are not older.

Being a teenager is different from being an adult. Teenagers' brains are still growing and changing. The part of the brain that helps us make good decisions and control our actions is not yet fully developed.

Because Gabriel was only 16, the court should have told the jury to think about his age when deciding if he was forced to do something bad. His age could have helped prove that he was not responsible for his actions because his brain was still developing.

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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, No. S.C. 17789 (Conn. Feb. 8, 2007).

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