Layman v. State
Juvenile Law Center filed an amicus brief in the Indiana Court of Appeals on behalf of Blake Layman and Levi Sparks. 16-year-old Layman and 17-year-old Sparks joined a third accomplice, 21-year-old Danzele Johnson in attempting to break into a house they thought was vacant. Tragically, not only was the home occupied, but the homeowner shot and killed Johnson. Though not the shooter, Appellants were convicted of murder under Indiana's felony murder statute.
Juvenile Law Center’s brief argued that their sentences conflict with U.S. Supreme Court precedent, as well as established research on adolescent brain science. Compared with adults, children and teenagers are less able to perceive and assess risks. They are less capable decision-makers than adults as they are more impulsive, less risk averse, and have difficulty assessing the consequences of their actions, often prioritizing short-term rewards over any potential long-term negative consequences.
Specifically, we argued that the Indiana Court of Appeals should bar the application of Indiana's felony murder statue to juveniles in light of the prevailing and uncontroverted scientific research about adolescent offending. In the alternative, the Court should adopt a presumption against imposing Indiana's felony murder statute on juvenile offenders who do not kill the victim, intend to kill the victim, or actually foresee that the victim might be killed in the course of the felony. At a minimum, Indiana should adopt an "agency" approach for juvenile offenders and hold that the felony murder doctrine does not apply if the person who causes the death is not the juvenile or one of his accomplices. Finally, if convicted of felony murder, juvenile offenders' sentences must be based on their own actions and culpability rather than consequences of their actions that they, as adolescents with poor risk-assessment skills, are unlikely to foresee.
On September 12, 2014, a divided Indiana Court of Appeals ruled against Layman and Sparks, although it also ordered their sentences to be reduced. Layman and Sparks subsequently appealed to the Indiana Supreme Court. On October 14, 2014, Juvenile Law Center filed an additional amicus brief supporting their appeals.
On September 18, 2015 the Indiana Supreme Court, based on the facts of the case, vacated the teens’ felony murder convictions and held that they should be re-sentenced only for the crime of burglary.