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Supreme Court bars mandatory life sentences for juveniles

Supreme Court ruling aims to give judges and juries an opportunity to consider 'mitigating circumstances' before sentencing a juvenile offender to life in prison, without possibility of parole.

By Staff writer / June 25, 2012

The Supreme Court ruled Monday that it is unconstitutional for state laws to require juveniles convicted of murder to be sentenced to life in prison without possibility of parole.

Evan Vucci/AP

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Washington

In a major decision issued Monday, the US Supreme Court struck down mandatory sentencing schemes requiring juvenile defendants to serve life in prison without the possibility of parole.

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Voting 5 to 4, the high court declared that automatically sentencing someone so young to a lifetime behind bars – with no future prospect than to die in prison – is cruel and unusual punishment in violation of the Constitution’s Eighth Amendment.

“The Eighth Amendment forbids a sentencing scheme that mandates life in prison without the possibility of parole for juvenile offenders,” Justice Elena Kagan wrote in the majority decision. “A judge or jury must have the opportunity to consider mitigating circumstances before imposing the harshest possible penalty for juveniles,” she said.

Justice Kagan said mandatory sentencing provisions eliminate the ability of a sentencing court to take into consideration all mitigating circumstances about a juvenile’s life and involvement in the crime before concluding that life without parole is appropriate punishment for a young offender.

“Although we do not foreclose a sentencer’s ability to make that judgment in homicide cases, we require it to take into account how children are different, and how those differences counsel against irrevocably sentencing them to a lifetime in prison,” she wrote.

Two justices, Stephen Breyer and Sonia Sotomayor, favored imposing a blanket ban on all life-without-parole sentences for juveniles. While rejecting that option, Kagan noted: “We think appropriate occasions for sentencing juveniles to this harshest possible penalty will be uncommon.”

Kagan said juvenile offenders should not be punished as harshly as adults, because they are generally less culpable than adults for their crimes, and enjoy a higher capacity to change. Studies have shown that judgment and character are not fully formed until an individual reaches his or her 20s.

The high court used that same rationale concerning the development of the brain and emotional maturity to justify two other landmark rulings – declaring the death penalty for juvenile offenders unconstitutional in 2005 and deciding in 2010 that sentencing a juvenile to life without parole for a non-homicide crime violated the Eighth Amendment. 

The deciding fifth vote in all three cases was cast by the same justice, Anthony Kennedy.

In a dissenting opinion, Chief Justice John Roberts said the Monday decision is not a logical extension of the court’s earlier holdings in 2005 and 2010.

“Those cases undoubtedly stand for the proposition that teenagers are less mature, less responsible, and less fixed in their ways than adults – not that a Supreme Court case was needed to establish that,” he said.

“What they do not stand for, and do not even suggest, is that legislators – who also know that teenagers are different from adults – may not require life without parole for juveniles who commit the worst types of murder,” he said.

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