Brief of Juvenile Law Center, Center on Wrongful Convictions of Youth, and Center for Law, Brain and Behavior as Amici Curiae in Support of Appellant Harrison
Brent Michael Pattison
Marsha L. Levick
Steven A. Drizin
Nancy Gertner
SimpleOriginal

Summary

The rationale underlying the felony murder doctrine contravenes (violates) Supreme Court jurisprudence as applied to juveniles.

2017 | Federal Juristiction

Brief of Juvenile Law Center, Center on Wrongful Convictions of Youth, and Center for Law, Brain and Behavior as Amici Curiae in Support of Appellant Harrison

Keywords transferred intent; adolescents; culpability; blameworthiness; foreseeability; risk-taking; neuroscience research; vulnerability to negative influences; felony murder
Open Amicus Brief as PDFScreenshot 2024-05-10 at 1.47.11 PM

Summary of Argument

When Keyon Harrison was sixteen-years-old, an adult acquaintance used him as an accomplice in a planned robbery of a neighborhood drug dealer. Harrison’s role was to lure the drug dealer to a location where the adult co-defendant would rob the dealer. The robbery went terribly wrong when the victim fought with Harrison’s adult co-defendant, the two struggled over the co-defendant’s gun, and the gun went off killing the victim. Even though Harrison was not armed, did not participate in the fight that led to the victim’s death, and did not expect, intend, or foresee that the victim would be killed, he was charged with first degree murder in the adult justice system, convicted of felony murder, and sentenced to life with the possibility of parole. This case raises fundamental questions about the fairness of applying Iowa’s broad felony murder statute to juvenile defendants in light of new developmental and neuroscientific findings about the reduced culpability of juvenile offenders.It also raises concerns about subjecting juvenile defendants to the same mandatory sentencing schemes as those applied to adults convicted of felony murder.

Amici write to urge this court to remand the case because evidence, rooted in law and science, demonstrates that young people must not be held liable under the theory of felony murder.

Summary

Keyon Harrison, a sixteen-year-old, was convicted of felony murder after being charged as an adult for his involvement in a robbery that resulted in the victim's death. While Harrison did not directly participate in the altercation that led to the victim's death and lacked intent or foreseeability of the fatal outcome, he was nonetheless held liable under Iowa's felony murder statute. This case raises critical concerns about the application of such a broad statute to juvenile defendants, particularly given emerging scientific understanding of the developmental and neurological differences impacting adolescent culpability. Additionally, subjecting juveniles to the same mandatory sentencing schemes as adults convicted of felony murder raises questions about fairness and proportionality.

Amici urge the court to reconsider Harrison's conviction, arguing that the scientific evidence and legal principles demonstrate the inappropriateness of applying the felony murder theory to young offenders.

Summary

Keyon Harrison, at the age of sixteen, was an accomplice in a robbery planned by an adult acquaintance. Harrison's role was to bring the intended victim, a drug dealer, to a location where the robbery would take place. The situation escalated when the victim resisted the robbery attempt, leading to a struggle over the co-defendant’s firearm. During the struggle, the firearm discharged, killing the victim. Despite Harrison not being armed, directly involved in the fight, or intending to cause harm, he was charged with first-degree murder in the adult justice system. He was ultimately convicted of felony murder and sentenced to life with the possibility of parole. This case presents a challenge to the application of Iowa's broad felony murder statute to juveniles. Specifically, it raises concerns about the fairness of such application, given contemporary research on the developmental and neurobiological factors that contribute to the diminished culpability of juvenile offenders. Additionally, the case raises questions about the appropriateness of imposing mandatory sentencing schemes, designed for adults, on juvenile defendants convicted of felony murder.

This brief argues that the court should remand the case to consider the compelling scientific and legal evidence that demonstrates the need for a more nuanced approach to holding juveniles accountable under the felony murder doctrine.

Summary

When Keyon Harrison was sixteen, he was involved in a robbery planned by an older acquaintance. Harrison's part was to bring the intended victim, a drug dealer, to a specific location. The robbery went wrong, and the victim was killed during a struggle. Even though Harrison didn't have a gun, didn't fight, and didn't intend for anyone to die, he was charged with murder as an adult. He was found guilty and sentenced to life in prison. This case highlights important questions about whether it's fair to apply Iowa's law on felony murder to teenagers. New research about how young people's brains develop suggests they may not be as responsible for their actions as adults. The case also raises concerns about giving teenagers the same harsh sentences as adults convicted of felony murder.

Those who support Harrison's case are urging the court to reconsider the decision, arguing that the law and scientific evidence show that young people should not be held responsible for murder under this specific law.

Summary

Keyon Harrison was only sixteen when he got mixed up in a robbery with an older person. Keyon's job was to trick a drug dealer into going to a certain place where the older person planned to steal from him. During the robbery, things went bad, and the drug dealer fought with the older person. They struggled over a gun, and it went off, killing the drug dealer.

Keyon didn't have a gun, he wasn't in the fight, and he never wanted anyone to get hurt, but he was still charged with murder. He was found guilty and sentenced to life in prison, even though he didn't kill anyone.

This case shows that it's not fair to hold young people responsible for murder just because they were involved in something bad. Scientists have learned a lot about how young brains work, and they know that young people don't think and make decisions the same way as adults. This court should take a closer look at this case and decide if it's fair to punish Keyon like a grown-up who committed murder.

Footnotes and Citation

Cite

Brief of Juvenile Law Center, Center on Wrongful Convictions of Youth, and Center for Law, Brain and Behavior as Amici Curiae in Support of Appellant Harrison, State v. Harrison, No. 16-1998 (Iowa Feb. 16, 2018).

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