Brief of Juvenile Law Center et al. in Support of Petitioner
Marsha L. Levick
Riya Saha Shah
Katherine E. Burdick
G. Ben Cohen
SimpleOriginal

Summary

Plea decisions weighing a death sentence against a sentence to die in prison are of the highest stakes, confounding a teenager’s ability to make a well-reasoned judgment and creating a coercive plea negotiation situation.

2018 | Federal Juristiction

Brief of Juvenile Law Center et al. in Support of Petitioner

Keywords juvenile life without parole; LWOP; coercive guilty plea; forced guilty plea; plea bargain; death penalty; plea negotiations; coercive plea negotiations; Roper; adolescent vulnerability; decision-making; adolescent's diminished legal competence; legal comprehension; mental impairments; brain; neurological vulnerability
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Summary of Argument

Mr. Newton was seventeen years old when he was presented with a Sophie’s choice: plead guilty to life without the possibility of parole, or face the real possibility of being sentenced to death. The principal use of capital punishment in the modern era has been to extract guilty pleas to other forms of harsh sentences. In Mr. Newton’s case, this prosecutorial practice was especially untenable due to his status as an adolescent, and the fact that this Court later declared unconstitutional the punishment that motivated Mr. Newton’s plea decision. See Roper v. Simmons, 543 U.S. 551 (2005). Mr. Newton’s sentence represents an unconstitutional vestige of the pre- Roper era, which this Court has not yet squarely considered.

Extensive jurisprudence from this Court, confirmed by neuro- and social science, makes clear that youth are uniquely vulnerable during plea negotiations. Plea decisions weighing a death sentence against a sentence to die in prison are of thehighest stakes, confounding a teenager’s ability to make a well-reasoned judgment. This Court has observed that our legal history is “‘replete with laws and judicial recognition’ that children cannot be viewed simply as miniature adults.” J.D.B. v. North Carolina, 564 U.S. 261, 273-74 (2011) (quoting Eddings v. Oklahoma, 455 U.S. 104, 115-16 (1982). This touchstone of the Court’s jurisprudence must apply to all aspects of criminal procedure that expose youth to harsh consequences—including the coercive guilty plea underlying the life without parole sentence here.

This Court’s understanding of the standards of decency has evolved since Mr. Newton was forced to make this impossible choice. See Stanford v. Kentucky, 492 U.S. 361 (1989), abrogated by Roper v. Simmons, 543 U.S. 551 (2005). It would be unconstitutional to impose this choice today. See Roper, 543 U.S. 551. Mr. Newton should not be forever trapped by the sentence imposed under these extraordinary circumstances. The Court should therefore grant certiorari to clarify that juvenile life without parole sentences, even those imposed by plea agreements, must be afforded the protections this Court laid out in Miller v. Alabama, 567 U.S. 460 (2012).

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Summary of Argument

In the case of Mr. Newton, the Supreme Court is presented with a legal dilemma involving the constitutionality of life without parole sentences imposed on juveniles through plea agreements. The argument presented is that such sentences are a vestige of a pre-Roper v. Simmons era, where the death penalty was used as a coercive tool to extract guilty pleas. This practice is deemed particularly egregious in the case of adolescents, whose cognitive and emotional immaturity renders them vulnerable during plea negotiations.

Extensive jurisprudence and scientific evidence demonstrate that juveniles possess diminished decision-making abilities compared to adults. The high-stakes nature of plea decisions involving the death penalty further exacerbates this vulnerability. The Supreme Court has consistently recognized the unique status of children in the criminal justice system, emphasizing that they cannot be treated as "miniature adults."

Since Mr. Newton's plea agreement, the Supreme Court's understanding of societal decency standards has evolved. In Roper v. Simmons, the Court declared the death penalty unconstitutional for juveniles. The same rationale should apply to life without parole sentences obtained through coercive plea agreements.

In Miller v. Alabama, the Supreme Court held that mandatory life without parole sentences for juveniles violate the Eighth Amendment. The Court should extend these protections to juvenile life without parole sentences imposed through plea agreements, recognizing the inherent vulnerability of adolescents in such high-stakes decisions.

Mr. Newton's sentence represents an unconstitutional remnant of a bygone era. The Supreme Court should grant certiorari to clarify that juvenile life without parole sentences, even those obtained through plea agreements, must be subject to the protections established in Miller v. Alabama. This would ensure that the evolving standards of decency and the unique vulnerabilities of juveniles are fully considered in the criminal justice system.

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Summary of Argument

When Mr. Newton was only 17, he had to make an impossible choice: plead guilty and spend the rest of his life in prison, or risk being sentenced to death. Prosecutors often use the threat of the death penalty to pressure defendants into accepting harsh plea deals.

Teenagers are not as mature as adults and may not fully understand the consequences of their decisions. When faced with the possibility of the death penalty, they may feel pressured to plead guilty, even if they are innocent.

Research has shown that teenagers:

  • Have difficulty weighing long-term consequences

  • Are more likely to be influenced by emotions

  • May not fully understand their legal rights

In 2005, the Supreme Court ruled that it was unconstitutional to execute people who were under 18 at the time of their crime. This decision recognized that teenagers are different from adults and should not be held to the same standards.

Mr. Newton's sentence is a reminder of the harsh punishments that teenagers faced before the Supreme Court's decision. The Court should now consider whether it is also unconstitutional to sentence teenagers to life without parole, even if they agree to a plea deal.

The Court has a responsibility to protect teenagers from unfair and excessive punishment. It should grant review in Mr. Newton's case and clarify that even teenagers who plead guilty are entitled to the same protections as those who go to trial.

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Summary of Argument

When Mr. Newton was 17, he had to make a terrible choice: admit he was guilty and spend the rest of his life in prison, or risk being sentenced to death. Prosecutors often use the threat of the death penalty to get people to plead guilty to lesser sentences. But in Mr. Newton's case, this was especially unfair to do this to him because he was a teenager. Later, the Supreme Court ruled that it was against the Constitution to sentence teenagers to death.

The Supreme Court has said that teenagers are different from adults. They're more likely to make bad decisions, especially when they're under pressure. When teenagers have to choose between dying in prison or facing the death penalty, it's almost impossible for them to think clearly.

When Mr. Newton made his choice, it was still legal to sentence teenagers to death. But since then, the Supreme Court has changed its mind. It would be wrong to force a teenager to make that choice today. Mr. Newton's sentence is a reminder of a time when teenagers could be sentenced to death. The Supreme Court should make it clear that even teenagers who plead guilty to life in prison should have the same protections as other teenagers who are sentenced to life in prison.

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Summary of Argument

Mr. Newton was only 17 when he had to make a really tough decision. He could either say he was guilty and spend the rest of his life in jail, or he could say he was not guilty and risk being sentenced to death.

It's not fair to make teenagers make these kinds of choices because their brains are still growing and they don't always think clearly. It's like asking a little kid to choose between eating broccoli or ice cream for the rest of their life.

The law used to allow teenagers to be sentenced to death, but now we know that's not right. So, Mr. Newton's sentence is like something from the old days that shouldn't be allowed anymore.

The people who want to help Mr. Newton say that he shouldn't have to stay in jail forever because he was just a kid when he made that hard choice. They want the court to make sure that teenagers who are forced to make these kinds of choices are protected.

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Footnotes and Citation

Cite

Brief of Amici Curiae Juvenile Law Center, The Promise of Justice Initiative, and Children and Family Justice Center in Support of Petitioner, Newton v. Indiana, No. 17-1511 (U.S. Feb. 20, 2018).

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