Brief of Juvenile Law Center, Defender Association of Philadelphia, Atlantic Center for Capital Representation, and Youth Sentencing and Reentry Project as Amici Curiae in Support of Appellant Avis Lee
Marsha L. Levick
Brooke McCarthy
Riya S. Shah
Bradley S. Bridge
Keir Bradford-Grey
SimpleOriginal

Summary

The imposition of life without parole sentences on young adults is categorically barred under the Eighth Amendment because young adults possess the same developmental characteristics as youth under 18.

2018 | State Juristiction

Brief of Juvenile Law Center, Defender Association of Philadelphia, Atlantic Center for Capital Representation, and Youth Sentencing and Reentry Project as Amici Curiae in Support of Appellant Avis Lee

Keywords brain; young adult; LWOP; disproportionate sentence; Eighth Amendment
Pennsylvania v Lee

Summary of Argument

In Miller v. Alabama, the United States Supreme Court ruled mandatory life without parole sentences unconstitutional for juveniles convicted of homicide. The Court, relying on the same underlying scientific research used to bar the death penalty for juveniles, held that children were less culpable than their adult counterparts because of their immaturity, impetuosity, susceptibility to peer influence, and greater capacity for rehabilitation. Modern research now indicates that individuals retain these characteristics well into their twenties. As young adults possess the same juvenile characteristics that the Supreme Court has determined reduce culpability, mandatory life without parole sentences for this population are also disproportionate under the Eighth Amendment. There is no penological justification for condemning a young adult to die in prison when they have the same capacity for reform as their younger counterparts and will serve a disproportionately long sentence due to their young age. Since Pennsylvania’s murder statute does not allow for individualized sentencing that accounts for a young person’s attendant characteristics of youth and requires mandatory imposition of life without parole, it must be ruled unconstitutional as applied to young adults.

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Summary of Argument

The landmark decision in Miller v. Alabama (2012) declared mandatory life without parole (LWOP) sentences for juveniles convicted of homicide to be unconstitutional. The Supreme Court's rationale rested on scientific evidence demonstrating that juveniles possess diminished culpability relative to adults due to their developmental immaturity, impulsivity, vulnerability to peer pressure, and enhanced potential for rehabilitation.

Contemporary research suggests that these characteristics of youth extend into young adulthood. Neurobiological studies indicate that brain development continues well into the twenties, affecting decision-making, impulse control, and emotional regulation. This evidence implies that young adults retain the same mitigating factors that reduce culpability in juveniles.

Therefore, mandatory LWOP sentences for young adults are similarly disproportionate under the Eighth Amendment. Such sentences fail to account for the distinctive characteristics of youth that mitigate culpability. Moreover, they result in excessively long periods of incarceration for individuals who entered the justice system at a young age.

Pennsylvania's murder statute mandates LWOP for all individuals convicted of murder, regardless of age. This lack of individualized sentencing consideration contravenes the principles established in Miller. Consequently, Pennsylvania's statute must be deemed unconstitutional as it applies to young adults, who possess the same diminished culpability and potential for rehabilitation as juveniles. The absence of a penological justification for condemning young adults to spend the rest of their lives in prison further supports this conclusion.

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Summary of Argument

In the landmark case of Miller v. Alabama, the Supreme Court ruled that it was unconstitutional to sentence juveniles (those under 18) to life in prison without the possibility of parole for homicide. The Court based its decision on scientific evidence showing that juveniles are different from adults in important ways: they are less mature, more impulsive, more likely to be influenced by their peers, and have a greater potential for rehabilitation.

Now, new research suggests that young adults (those aged 18 to 25) also possess these same characteristics that make them less culpable than adults. This raises the question of whether mandatory life without parole sentences are also unconstitutional for young adults.

There is no good reason why a young adult who commits a crime should be condemned to die in prison. They have the same potential for rehabilitation as juveniles and will face a longer prison sentence than an older adult who commits the same crime. This is because they will live longer and therefore spend more years behind bars.

Pennsylvania's murder statute does not allow judges to consider the individual characteristics of young adults when sentencing them. Instead, it requires the automatic imposition of life without parole. This is unconstitutional as applied to young adults because it violates the Eighth Amendment's prohibition on disproportionate punishment. Young adults, like juveniles, deserve a chance at rehabilitation and the possibility of a second chance.

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Summary of Argument

In a previous case, the Supreme Court decided that kids who commit murder shouldn't automatically get life in prison without the possibility of parole. They said that kids are different from adults because they're not as mature, they act without thinking, they can be easily influenced by their friends, and they have a better chance of changing for the better.

Now, scientists have learned that people in their early twenties still have these same traits. So, just like kids, young adults shouldn't automatically get life in prison without parole either. It's not fair to make them spend the rest of their lives behind bars when they can still change and become better people.

Plus, young adults would end up spending way more time in prison than older people who commit the same crimes. That's because they're starting their sentences at a younger age.

In Pennsylvania, the law says that anyone who commits murder has to get life in prison without parole, no matter how young they are. But since young adults have the same qualities that make kids less responsible for their crimes, this law is unfair to them. It should be changed so that young adults don't automatically get such a harsh punishment.

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Summary of Argument

The Supreme Court said that when kids or teens do something really bad, like kill someone, they shouldn't have to go to jail for the rest of their lives. They said that kids and teens are different from adults because their brains aren't finished growing yet. They don't think things through as well, they're more likely to do things without thinking, and they can change and become better people more easily than adults.

Now, scientists have found out that young adults, people in their early twenties, are still a lot like kids in these ways. They still have some of the same problems with thinking and making good choices. So, it's not fair to make them go to jail forever either. It's like punishing someone for a long time because they're young.

In Pennsylvania, if you kill someone, you have to go to jail for life, no matter how old you are. But that's not right for young adults, because their brains are not done growing and they can change their behavior easier than adults. They should have a chance to show that they can change and become good people again.

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Footnotes and Citation

Cite

Brief of Amicus Curiae Juvenile Law Center, Defender Association of Philadelphia, Atlantic Center for Capital Representation, and Youth Sentencing and Reentry Project in Support of Appellant Avis Lee, Commonwealth v. Lee, No. 1891 WDA 2016 (Pa. Super. Ct. May 9, 2018).

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