Brief of NAACP et al. in Support of Petitioners
Vincent M. Southerland
John Payton
Debo P. Adegbile
Christina A. Swarns
Jin Hee Lee
SummaryOriginal

Summary

The Eighth Amendment demands fair evaluation of culpability, but proper evaluation of culpability has been undermined by the racially charged criminalization of youth of color.

2012 | Federal Juristiction

Brief of NAACP et al. in Support of Petitioners

Keywords Eighth Amendment (U.S.); culpability evaluation; race; juvenile; youth; juvenile LWOP; juvenile life without parole; African American; Latino; "wilding"; superpredators

The question presented by these cases is whether the imposition of a life without parole sentence on a fourteen-year-old child convicted of a homicide offense violates the Eighth and Fourteenth Amendments’ prohibition against cruel and unusual punishments. As detailed by the submissions of the Petitioners and their amici curiae, the answer is “yes.” As this amicus brief explains, the improper influence of race impairs the culpability analyses of children subject to life without parole sentences, which is further evidence of the unconstitutionality of this sentencing practice. Although a proper evaluation of culpability is fundamental under the Eighth and Fourteenth Amendments, history shows that racial stereotypes propelled the implementation of the laws that led to juvenile life without parole sentences, and research establishes that children of color are sentenced to life without parole at markedly disproportionate rates. This Court declared, in Graham v. Florida, 560 U.S. ___, 130 S. Ct. 2011 (2010), that youth are less culpable than adults and, therefore, less deserving of life without parole sentences. Yet, it is clear that race critically and inappropriately influences the assessment of blameworthiness in the context of juvenile life without parole sentencing. Given this constitutional infirmity, as well as the severity and finality of a death-in-prison sentence, this Court should categorically exempt youth from life without parole sentences.

Summary

Introduction

The constitutionality of life without parole (LWOP) sentences for juvenile homicide offenders is a pressing legal issue. This article examines the detrimental impact of racial bias on culpability assessments in such cases, arguing that it renders LWOP sentences unconstitutional under the Eighth and Fourteenth Amendments' prohibition against cruel and unusual punishments.

Racial Disparities and the History of LWOP Sentencing

Historical evidence demonstrates that racial stereotypes played a significant role in the implementation of laws leading to juvenile LWOP sentences. Research indicates that children of color face disproportionately higher rates of LWOP sentencing compared to their white counterparts.

Culpability and the Influence of Race

In Graham v. Florida (2010), the Supreme Court recognized the diminished culpability of youth compared to adults, making LWOP sentences less appropriate for juveniles. However, racial bias can distort the assessment of blameworthiness in juvenile LWOP sentencing. Implicit and explicit biases can lead to harsher judgments against children of color, undermining the fairness of culpability determinations.

Conclusion

The improper influence of race on culpability assessments in juvenile LWOP sentencing violates the Eighth and Fourteenth Amendments. Given the severity and finality of LWOP sentences, the Court should categorically prohibit their imposition on youth to ensure constitutional protections and address the systemic racial disparities in the criminal justice system.

Summary

The Issue:

Should 14-year-old children convicted of murder receive life sentences without the possibility of parole? The Eighth and Fourteenth Amendments prohibit cruel and unusual punishment, and this question raises concerns about whether such sentences are appropriate for minors.

The Argument:

Children are less responsible for their actions than adults, and therefore should not receive the same harsh punishments. However, racial bias has historically influenced the implementation of juvenile life sentences, and children of color are disproportionately sentenced to life without parole.

Evidence of Racial Bias:

  • History shows that racial stereotypes played a role in creating laws that allowed for juvenile life sentences.

  • Research indicates that children of color are more likely to receive these sentences than white children.

Impact on Culpability:

Race should not be a factor in determining a child's blameworthiness. However, racial bias can lead to unfair assessments of guilt and responsibility.

Conclusion:

Given the evidence of racial bias and the severity of life without parole sentences, the Court should prohibit such sentences for children.

Summary

The question is: Should 14-year-olds who commit murder get life in prison without the chance of getting out? The Constitution says that punishments can't be cruel or unusual.

Kids who get this sentence argue that it's unfair because they're not as responsible for their actions as adults. They also say that racism plays a role in who gets this sentence. Black and brown kids are more likely to get life without parole than white kids.

Research shows that kids are less to blame for their actions than adults. But when it comes to sentencing kids to life without parole, race seems to make a difference. This is a problem because it's not fair to punish kids differently based on their race.

Because of these problems, some people believe that no child should ever get life in prison without parole.

Summary

Some kids who are 14 years old have been given a very serious punishment: life in prison without the chance to get out. Some people think this is too harsh of a punishment for kids.

Kids are different from adults, and they don't always understand the consequences of their actions. They also have a better chance of changing and becoming good citizens.

But there's another problem: kids of color are more likely to get this punishment than white kids. This is because of unfair stereotypes and biases.

Because of these reasons, some people believe that kids should never be sentenced to life in prison without parole. They think it's cruel and unusual punishment.

Footnotes and Citation

Cite

Brief of Amici Curiae NAACP Legal Defense & Educational Fund, Inc., et al., Miller v. Alabama, Nos. 10-9646 & 10-9647 (U.S. Oct. 12, 2011).

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