Commonwealth v. Brooker
Juvenile Law Center, together with the Defender Association of Philadelphia and Sara Jacobson of Temple University, wrote an amicus brief challenging the constitutionality of Pennsylvania’s Act 204 of 2012.
After the United States Supreme Court in Miller v. Alabama declared unconstitutional Pennsylvania’s mandatory life without parole sentences for juveniles convicted of first or second degree murder, Pennsylvania responded by enacting Act 204. Act 204 left life without parole as an option for juveniles convicted of first degree murder and imposes severe mandatory minimum sentences as the only alternative option. Juvenile Law Center argued that Act 204 is unconstitutional on numerous grounds. First, Act 204 violates Article III, Section 1 of the Pennsylvania Constitution because the purpose of the bill dramatically changed during the legislative process. Second, the Act violates Article III, Section 2 of the Pennsylvania Constitutional because it contains more than one subject.
Juvenile Law Center also argued the harsh sentences for juveniles violate the U.S. Supreme Court’s holdings in Miller and Graham v. Florida. Finally, Juvenile Law Center argued that the Act violates the Ex Post Facto clauses of the United States and Pennsylvania Constitutions.
The trial court found the Act to be constitutional.
In February 2014, Juvenile Law Center and the Defender Association of Philadelphia filed a brief on behalf of Mikechel Brooker, arguing that the evidence is insufficient to find Brooker guilty of first degree murder because the Commonwealth failed to establish "beyond a reasonable doubt" that he had the specific intent to kill, and that Act 204 is unconstitutional for all the reasons stated above.
The Pennsylvania Superior Court affirmed the lower court, rejecting Mr. Brooker’s sufficiency argument as well as his constitutional challenges to Act 204.
Juvenile Law Center and the Defender Association of Philadelphia appealed to the Pennsylvania Supreme Court. The petition for allowance of appeal was denied.