Juvenile Life Without Parole
This guidebook from National Conference of State Legislatures provides information on current youth justice policy at the federal and state level exploring a range of youth justice policy areas rom age of juvenile court jurisdiction and transfer into adult court to diversion and probation. From the introduction: “Today, a sound body of youth justice law…
The D.C. Court of Appeals held that age and youthfulness should be considered as mitigating evidence in sentencing reconsiderations pursuant to D.C.’s Incarceration Reduction Amendment Act. The court stated in relevant part: As our prior decisions have made clear, the “[District of Columbia] Council initially passed the IRAA in response to several ‘constitutional imperatives’ declared…
The Illinois Court of Appeals found that the trial court erred in applying the statutory framework when resentencing Evans under Miller and that the severity of the offense does not relieve the court of the duty to follow the law. The Court of Appeals remanded the case for a new sentencing hearing. The court reasoned in…
The Washington Court of Appeals held that Leo suffered substantial prejudicial error when the trial court only considered his age for his murder convictions in his Miller hearing and did not consider his age for the remaining convictions and therefore remanded his case for resentencing. The court stated in relevant part: “We conclude that Leo has proven…
The Court of Appeals of Washington remanded a case for resentencing finding that the trial court abused its discretion by “failing to place greater emphasis on Thang’s mitigating qualities of youth during resentencing,” pursuant to the Miller decision. The court stated in relevant part: “We agree with Thang that this analysis shows that the sentencing…
The Illinois 1st District Court of Appeals held that a statutory minimum sentence that effectively amounted to a de facto life sentence as applied to youth violated the Eighth Amendment’s prohibition on cruel and unusual punishment. The court reasoned that the core takeaway of Miller v. Alabama is that “there must be an exercise of…
This report from the Campaign for the Fair Sentencing of Youth provides a national overview of the progress states have made post-Montgomery in changing sentencing laws for young people in adult court facing life without parole and other lengthy sentences, and opportunities for continued legislative, legal and policy change. From the resource: Ten years ago, the…
The Second District Court of Appeals in Illinois vacated a 66-year sentence finding that the trial court misinterpreted youth-related statutory factors as aggravating instead of mitigating factors. The court stated in relevant part: “Defendant also argues that the trial court incorrectly interpreted the statutory factor of his ability to consider the risks and consequences of…
The Oregon Court of Appeals examined a state sentencing statute that prohibits juvenile life without parole sentences (ORS 161.740) and held that it applies when an individual is convicted in adult court and sentenced for an offense committed when they were under the age of 18 if the sentence was imposed on or after January…
The Michigan 1st District Court of Appeals vacated second-degree murder and assault with the intent to commit murder sentences for an individual who was 18 years old at the time of the incident and remanded with instructions for the trial court to consider youthfulness and its attendant characteristics as mitigating factors. The court stated in…
The Supreme Court of Michigan held that the trial court’s analysis of Appellant’s case pursuant to the Miller factors and resentencing to LWOP was improper and remanded the case for reconsideration under the proper framework. The court stated in relevant part: “Notably, as defendant identifies, the trial court relied on the fact that defendant has…
“Life without parole is the harshest sentence a minor can receive for a homicide offense. Florida is one of a few states that still allow this type of sentence for minors. This sentence violates the Eighth Amendment of the Constitution because it is a cruel and unusual punishment as it locks up a minor for…
The Supreme Court of Montana reversed a trial court’s decision denying a sentence reduction for a young adult who was convicted of a homicide offense when he was 16 years old. Noting that transferring a youth to adult court cannot mean that the state “forget[s] about his age,” the Court relies on the juvenile court…
On April 10, 2025, the Supreme Court of Michigan extended its 2022 decision in People v. Parks, which declared mandatory life without parole (LWOP) for 18-year-olds unconstitutional, to also apply to 19- and 20-year-olds. Relying on the state’s constitutional prohibition against “cruel or unusual punishment,” the Court found that mandatory LWOP for 19- and 20-years…
From the introduction: “Morris Mullins pled guilty to aggravated murder and was sentenced to life without parole (LWOP). Because he was seventeen years old when he committed the crime, this is a juvenile life without parole (JLWOP) sentence. Now, at age forty and having already spent more than two decades in prison, Mullins challenges his…
The evidence provided in this brief supports bold reforms for youth and emerging adults sentenced to extreme punishments.
The National Youth Justice Network released a report detailing legislative trends on youth rights from 2023. This report highlights key gains made by several states around juvenile court fines and fees, expungement, transfer, and youth interrogation among other issues, and flags several regressive legislative trends rooted in harmful narratives about young people. This overview of…
This amicus brief from the Center for Law, Brain, and Behavior highlights the adolescent capacity for significant growth and social maturation as well as criminological evidence on the unlikelihood of reoffending and responsiveness to evidence-based treatment among youth accused of sex offenses. The brief ultimately calls for the court to find that a de facto life without parole sentence is grossly disproportionate based on developmental science and research. From the Summary of Argument: “Evan McCarrick Jerald is…
Abstract: “While there has been momentum at both the federal and state levels to curtail extreme punishments for justice-involved juveniles (The Campaign for the Fair Sentencing of Youth, 2023), 22 states continue to permit the sentence of juvenile life without parole (JLWOP). Pennsylvania is among them. This essay focuses on judicial rationale in five JLWOP re-sentencing cases in…
This report presents the evolution of the second look movement, which started with ensuring compliance with the U.S. Supreme Court’s decisions in Graham v. Florida (2010) and Miller v. Alabama (2012) on the constitutionality of juvenile life without parole (“JLWOP”) sentences.12 This reform has more recently expanded to other types of sentences and populations, such…
A concentration of a few states has unevenly complied with Miller and the possibility of resentencing provided by Montgomery. Some states have refused to comply at all. This uneven implementation of the Miller decision has a particularly profound impact on racial disparities among those serving JLWOP. An analysis of those deemed worth protecting from JLWOP…
