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. 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 critical issue concerning the application of Graham v. Florida and the significance of Miller v. Alabama to the Court's Eighth Amendment jurisprudence as it pertains to minors. The Court established in Graham that juvenile offenders cannot receive life imprisonment without parole unless they are offered a substantial and realistic chance to reintegrate into society before their sentence's expiration for non-homicide offenses. The Court elaborated on this point, stating that:

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.

Graham asserted that a sentence that does not provide a "meaningful opportunity to obtain release" before the end of the child's life violates the Constitution. In this case, the Petitioner received a sentence that effectively confines him to prison until he reaches approximately 105 years of age for non-homicide offenses committed during his childhood. Since this sentence guarantees Petitioner's death in prison, the Court should clarify that this sentence is unconstitutional under Graham regardless of whether it is formally labeled as "life without parole." According to Graham, juveniles who are not convicted of murder or intent to kill must be assured a "meaningful opportunity to obtain release," even if this opportunity does not lead to actual release. Chaz Bunch was denied this opportunity when he received a sentence of years that is practically equivalent to a life sentence. As Chaz Bunch did not commit murder or intend to kill, he is not deserving of "this harshest possible penalty."

Summary of Argument

This case examines the applicability of Graham v. Florida and Miller v. Alabama to Eighth Amendment jurisprudence regarding juvenile offenders.

Graham established that juveniles cannot receive life-without-parole sentences for non-homicide offenses without a realistic opportunity for reintegration into society. The Court recognized that juveniles need the chance to mature and develop self-awareness. A life sentence without parole denies them this opportunity, offering no hope of reconciliation with society.

The ruling in Graham emphasized that a sentence must provide a "meaningful opportunity to obtain release" before the end of a juvenile's life. In this case, the petitioner was sentenced to a term of years that effectively guarantees he will die in prison, which, according to Graham, is unconstitutional regardless of the specific wording of the sentence.

The Court should recognize that a sentence functionally equivalent to life imprisonment violates the principles of Graham, even if it is not labeled "life without parole." Juvenile offenders who did not kill or intend to kill, such as the petitioner, should have a "meaningful opportunity" for release, as mandated by Graham. This principle is further supported by Miller v. Alabama, which ruled that life sentences without parole are inappropriate for juveniles who did not commit murder.

Summary of Argument

This case is about how laws related to sentencing young people should be applied. The Supreme Court has ruled that young people who commit crimes should not be sentenced to life in prison without the possibility of ever getting out, especially for crimes that are not murder.

The Court said that young people need a chance to grow up, learn from their mistakes, and become responsible members of society. A life sentence without the possibility of parole takes away this chance.

In this case, Chaz Bunch was sentenced to a very long prison term, which is basically the same as a life sentence. He will most likely die in prison for crimes he committed when he was young.

The Court needs to decide if this sentence is legal, even though it's not technically called "life without parole." Because Chaz Bunch didn't kill anyone, he should have a chance to get out of prison, even if it doesn't mean he will actually be released. The Court needs to ensure that young people who don't commit murder have a "meaningful opportunity" to get out of prison, as the Supreme Court has already ruled.

Summary of Argument

This case is about a young man named Chaz Bunch who was sentenced to a very long time in prison. The court is trying to figure out if this sentence is fair.

The court has already decided that children who commit crimes that don't involve killing someone shouldn't be given a sentence where they can never get out of prison. The court said this is because kids are different from adults and they have a chance to change and become better people.

Chaz Bunch was sentenced to a very long time in prison, even though he didn't kill anyone. So, the court needs to decide if his sentence is fair because it's basically like a life sentence. The court needs to make sure Chaz Bunch has a chance to get out of prison someday, even though he will be very old by then.