Summary of Argument

This case raises a question of exceptional importance regarding the application of Graham v. Florida and the importance of Miller v, Alabama to the Court’s Eighth Amendment jurisprudence as it relates to children. This Court ruled in Graham that juvenile offenders cannot be sentenced to life without parole without a meaningful and realistic opportunity to re-enter society prior to the expiration of their sentences for non-homicide offenses. 130 S. Ct. 2011, 2010 (2010). The Court explained:

The juvenile should not be deprived of the opportunity to achieve maturity of judgment and self-recognition of human worth and potential. . . . Life in prison without the possibility of parole gives no chance for fulfillment outside prison walls, no chance for reconciliation with society, no hope.Id. at 2032. Graham held that a sentence that provides no “meaningful opportunity to obtain release” before the end of the child’s life is unconstitutional.

Id. at 2033. Here, Petitioner was sentenced to remain in prison until he is approximately 105 years old for non-homicide offenses for which he was charged when he was a child.3 Because this sentence means that Petitioner unquestionably will die in prison, this Court should clarify that this sentence is unconstitutional under Graham regardless of whether it is actually labeled “life without parole.” Under Graham, juveniles who do not kill or intend to kill must be guaranteed a “meaningful opportunity to obtain release” -- even if that opportunity does not actually result in release. 130 S.Ct. at 2030. Chaz Bunch was denied that opportunity when he was sentenced to a term of years that is functionally equivalent to a life sentence. As Chaz Bunch did not kill or intend to kill, he is not deserving of “this harshest possible penalty.”. Miller v. Alabama, 132 S. Ct. 2455, 2469 (2012).

Summary of Argument

This case presents a significant question regarding the application of the Supreme Court's rulings in Graham v. Florida and Miller v. Alabama to Eighth Amendment jurisprudence as it pertains to juvenile offenders. In Graham, the Court held that sentencing juvenile offenders to life without parole for non-homicide offenses is unconstitutional unless they have a meaningful opportunity for release before the end of their lives. The rationale behind this decision was that juveniles should have the chance to mature, develop a sense of self-worth, and potentially reintegrate into society.

Under Graham, a sentence that effectively guarantees a juvenile offender will die in prison is deemed unconstitutional. In the present case, the petitioner was sentenced to a term of imprisonment that would keep him incarcerated until the age of 105 for non-homicide offenses committed as a child. This sentence functionally amounts to life imprisonment, denying the petitioner any meaningful chance of release.

The Court is urged to clarify that such sentences are unconstitutional under Graham, regardless of whether they are explicitly labeled as "life without parole." The principle established in Graham mandates that juveniles who do not commit homicide or intend to kill must have a genuine opportunity for release, even if that opportunity does not ultimately materialize. The petitioner in this case was deprived of that opportunity, and his sentence is therefore inconsistent with the Eighth Amendment's prohibition on cruel and unusual punishment. As the Supreme Court stated in Miller v. Alabama, the "harshest possible penalty" is inappropriate for juveniles who do not take a life or intend to do so.

Summary of Argument

In the case of Graham v. Florida, the Supreme Court ruled that children who commit non-homicide crimes cannot be sentenced to life in prison without the possibility of parole. This decision was based on the idea that children have the potential for rehabilitation and should not be deprived of the chance to become productive members of society.

In the present case, the petitioner, Chaz Bunch, was sentenced to prison until he is approximately 105 years old for non-homicide offenses he committed as a child. This sentence effectively means that he will die in prison. The argument is that this sentence violates the principles established in Graham, even though it is not technically a "life without parole" sentence.

According to Graham, children must have a "meaningful opportunity" to be released from prison, even if they are not actually granted release. This means that sentences that are so long that they guarantee the child will die in prison are unconstitutional. In the case of Chaz Bunch, his sentence denies him this opportunity and is therefore excessive and cruel.

Furthermore, in Miller v. Alabama, the Supreme Court recognized that children are different from adults and should not be subject to the "harshest possible penalty." As Chaz Bunch did not commit murder, he does not deserve such an extreme punishment.

Summary of Argument

This case is about a really important issue: should kids who commit crimes be sentenced to life in prison without the possibility of ever getting out? The Supreme Court has already said that kids can't be sentenced to life without parole for crimes that don't involve murder. This is because kids are still growing and changing, and they need a chance to prove that they can become responsible adults.

In this case, a kid named Chaz Bunch was sentenced to prison for so long that he'll probably die there, even though he didn't kill anyone. The Court is being asked to decide if this is fair. The argument is that even if Chaz's sentence doesn't say "life without parole," it's basically the same thing because he'll never have a chance to get out of prison.

According to the Supreme Court, kids who don't kill anyone should have a "meaningful opportunity" to be released from prison someday. This means that even if they don't actually get out, they should at least have the chance to prove that they've changed and deserve a second chance. Chaz Bunch was never given that opportunity, and the Court is being asked to decide if that's constitutional.

Summary of Argument

This case is about a boy named Chaz Bunch who was sent to jail when he was a kid for crimes he did, but he didn't kill anyone. He's going to be in jail until he's a very, very old man, about 105 years old. That means he'll probably die in jail.

The court says that's not fair for kids who don't kill anyone. They should have a chance to get out of jail someday and show that they've changed. Even if they don't get out right away, they should at least have some hope that they might.

Chaz Bunch didn't get that chance. His sentence is basically the same as if he had killed someone, even though he didn't. The court says that's not right. Kids who don't kill anyone shouldn't have to spend their whole lives in jail without any chance of getting out.