State v. Ramos

Juvenile Law Center, in collaboration with Teamchild, filed an amicus brief in the Supreme Court of Washington in support of Joel Ramos. Mr. Ramos was sentenced to 85 years for three counts of felony murder and 1 count of premeditated murder resulting from a robbery that he participated in less than a month after turning 14. Our brief argued that prior to imposing a harsh adult sentence on a juvenile offender, a sentence must consider the youth’s age and age-related characteristics as required by United States Supreme Court jurisprudence. We further argued that Graham and Miller affirm the United States Supreme Court’s recognition that children are categorically less deserving of the harshest forms of punishment.

The Washington Supreme Court stated in its opinion, “We now join the majority of jurisdictions that have considered the question and hold that Miller does apply to juvenile homicide offenders facing de facto life-without-parole sentences.” The Court further opined that “nothing about Miller suggest its individualized sentencing requirement is limited to [cases involving] single homicides. . . . Whether that sentence is for a single crime or an aggregated sentence for multiple crimes, we cannot ignore that the practical result is the same.” Additionally, the Court held that a “juvenile cannot forfeit his or her right to a Miller hearing merely by failing to affirmatively request it.”

However, the Court ultimately held that Mr. Ramos did in fact receive a Miller hearing which “met minimal federal constitutional requirements.” The Court also placed the burden on the defendant to show by a preponderance of the evidence that his crime reflected “transient immaturity.”