Amicus Curiae Brief of the Students of Father Gabriel Richard High School, Ann Arbor, Michigan
Jon R. Muth
Patrick M. Jaicomo
SimpleOriginal

Summary

Children are immature and impulsive, and can be reckless decision-makers, but they can and will change. This brief was written by a student and signed by 450 students.

2014 | State Juristiction

Amicus Curiae Brief of the Students of Father Gabriel Richard High School, Ann Arbor, Michigan

Keywords Eighth Amendment; LWOP; life without parole; immaturity; characteristics of youth; capacity for change; decision-making; impulsivity
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Summary of Argument

Miller Johnson, by Jon R. Muth and Patrick M. Jaicomo, is honored to be able to represent the Amicus Brief of 450 students (out of a total student body of approximately 530) at Father Gabriel Richard High School in Ann Arbor. Michigan. Attached as Exhibit A are the signatures of all 450 students. Our role as counsel has been only to attend to formal requirements and assure that the citations are accurate. While certain formal requirements of primary appellate briefs may be still lacking, what is significant here is the voice of the students. They bring a unique and important perspective to the question of how society and the law are to deal with juvenile offenders. Every word in this brief from the end of this sentence to the concluding valediction is theirs, with primary drafting credit to Marilyn Sarosi, a high school junior.

Amici are not constitutional scholars with an expertise in the 8th Amendment. We're not psychologists who study children and their cognitive, emotional and psychological development. Amici are members of the Student Body of Father Gabriel Richard High School in Ann Arbor ("FGR"). As high school students, ages 14-18, we live and breathe the traits and characteristics laid out in the U.S. Supreme Court rulings of Miller, Roper and Graham. We can testify to the overwhelming impact that our environment and peer pressure have on our daily life. Moreover, our Catholic faith guides our belief in the redemptive capacity of people, especially children, and limits the vengeful response that would keep children imprisoned until death. We bring a unique perspective that no other group can bring and as participants in Michigan's future. We have an interest in assuring that our Michigan justice system is truly blind and balanced.

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Summary

Miller Johnson, representing the Amicus Brief of 450 students (out of a total student body of approximately 530) at Father Gabriel Richard High School in Ann Arbor, Michigan, presents the students' voices on the topic of juvenile offenders. The students, led by junior Marilyn Sarosi, emphasize their unique perspective, informed by their experiences as teenagers.

The students, ages 14-18, recognize the significant impact of their environment and peer pressure on their daily lives. This perspective aligns with the U.S. Supreme Court rulings in Miller, Roper, and Graham, which acknowledge the developmental differences between adults and juveniles. The students' Catholic faith further informs their belief in the capacity for redemption, particularly among youth, advocating for a justice system that emphasizes rehabilitation over punishment.

As future members of Michigan society, the students express their desire for a justice system that is fair and balanced, ensuring that all individuals are treated equally.

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Summary

Miller Johnson, represented by Jon R. Muth and Patrick M. Jaicomo, is proud to submit an Amicus Brief on behalf of 450 students (out of approximately 530) at Father Gabriel Richard High School in Ann Arbor, Michigan. The signatures of all 450 students are included as Exhibit A. The attorneys have ensured the brief meets formal requirements and that all citations are accurate. While some formal elements of an appellate brief may be missing, the most important aspect of this brief is the voice of the students. They provide a unique and important perspective on how society and the law should treat juvenile offenders. Every word in this brief, from this point forward to the conclusion, is written by the students, with primary drafting credit given to Marilyn Sarosi, a high school junior.

The students are not legal scholars with expertise in the 8th Amendment, nor are they psychologists specializing in child development. They are students at Father Gabriel Richard High School ("FGR") in Ann Arbor. As teenagers aged 14-18, they experience firsthand the influences of their environment and peer pressure, as described in the Supreme Court cases of Miller, Roper, and Graham. They can attest to the significant impact these factors have on their daily lives. Furthermore, their Catholic faith guides their belief in the potential for redemption in all individuals, especially children, and discourages harsh punishments that would imprison children for life. Their perspective is unique and vital, as they are the future of Michigan. They are invested in ensuring that the Michigan justice system is fair and unbiased.

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Summary

Miller Johnson, a law firm, is representing 450 students from Father Gabriel Richard High School in Ann Arbor, Michigan. The students are asking the court to think about how society should treat young people who commit crimes. They believe that young people are different from adults and need to be treated differently by the law.

The students are not experts in law or psychology, but they are teenagers who understand the challenges of growing up. They know that peer pressure and their environment can influence their choices. They also believe in forgiveness and that young people can change.

The students want to make sure that Michigan's justice system is fair and treats everyone equally, regardless of their age. They believe that young people deserve a chance to be rehabilitated and become productive members of society.

Open Amicus Brief as PDF

Summary

Miller Johnson, a group of lawyers, is helping 450 students from Father Gabriel Richard High School in Michigan. The students want to share their thoughts about how the law should treat kids who break the law. They wrote a letter to the court called a "brief" and it's full of their ideas. The students think that kids who do wrong things can still change and become better people. They believe that everyone deserves a chance to get better, even kids who make mistakes. The students want the court to be fair and give kids a chance to change their lives.

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Footnotes and Citation

Cite

Brief of the Students of Father Gabriel Richard High School, Ann Arbor, Michigan as Amici Curiae in Support of Defendant-Appellant, People v. Carp, People v. Davis, People v. Eliason, Nos. 146478, 146819, 147428 (Mich. Feb. 14, 2014).

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