Commonwealth v. Knox

Juvenile Law Center, in collaboration with the Defender Association of Philadelphia and faculty at Temple University Beasley School of Law, Florida Coastal School of Law, and the University of San Francisco School of Law, filed this amicus brief in the Pennsylvania Superior Court on behalf of Jovon Knox. Mr. Knox was convicted of felony murder and was sentenced to life without the possibility of parole. At the time of the crime, Mr. Knox was seventeen-years-old. 

In the brief, Juvenile Law Center argues that a mandatory sentence of life without parole for a juvenile convicted of felony murder violates both the United States and Pennsylvania Constitutions as well as international law.  In Graham v. Florida, the United States Supreme Court considered the constitutionality of a life without parole sentence imposed upon a juvenile convicted of a non-homicide offense.  The Court held the sentence unconstitutional, grounding its decision in developmental and scientific research demonstrating that juveniles possess a greater capacity for rehabilitation than adults, and reasoning that the sentence therefore served no legitimate penological purpose when applied to juveniles.  Graham stated that such a sentence was unconstitutional when applied to juveniles who did not kill or intend to kill.  Because there was no finding in this case that Mr. Knox killed or intended to kill, the brief argues that his sentence is unconstitutional pursuant to Graham.

The Pennsylvania Superior Court held that Mr. Knox’s mandatory sentence of life without parole is unconstitutional, pursuant to the U.S. Supreme Court’s recent decision in Miller v. Alabama, and remanded the case for resentencing.