AAPL Landmark - Juvenile Rights Flashcards
Are juvenile delinquents facing a loss of liberty entitled to similar procedural due process rights as adults charged with a crime?
Yes.
In Re Gualt (1967). Child locked away for obscene phone calls. The USSC determined that the potential loss of liberty associated with delinquency hearings demands procedural safeguards, similar to adults charged with a crime, under the Due Process Clause of the 14th Amendment.
Does the Eighth Amendment permit the sentencing of a juvenile offender to life without parole for committing of nonhomicide crime?
No.
Graham v. Florida (2010). The USSC heard the case and, based on the proportionality principle (whether the punishment if proportional to the offense), concluded that the 8th Amendment prohibits sentences of life without parole for nonhomicide defendants younger than 18, and that states must provide such defendants with “some meaningful opportunity” for release.
Does the Eighth Amendment permit mandatory sentencing of a juvenile offender convicted of murder to life without parole?
No.
Miller v. Alabama (2012). The USSC found that the mandatory sentencing guidelines for murder in Alabama and Arkansas, regardless of offender age, violated the 8th Amendment’s ban on cruel and unusual punishment because adolescents are, by their developmental immaturity, less culpable and therefore less deserving of the most severe punishments. The Court did not categorically ban imposition on such a sentence but required consideration of the factors of youth in sentencing decisions.
