Argued that Petitioner's sentence is the equivalent of life without parole because Missouri law requires him to serve a minimum of 92 years before becoming parole-eligible. This sentence therefore violates the United States Supreme Court’s ruling in Graham v. Florida, which held that juvenile offenders cannot be sentenced to life for non-homicide offenses without a meaningful and realistic opportunity for re-entry into society prior to the expiration of their sentence.
We argued that research in adolescent development and neuroscience confirm that life without parole sentences categorically are unconstitutional when applied to children.
We argued that parole availability does not remedy a sentencing court's failure to give mitigating effect to the youth-related factors set forth in Miller.
We argued that Maryland's parole system is an unconstitutional ad hoc executive clemency system which fails to provide a "meaningful opportunity to obtain release" to youth sentenced to life or life equivalent terms.
We argued that juvenile adjudications are insufficient "to alone sustain proof beyond a reasonable doubt of an element of [an adult felony]" because it contradicts the rehabilitative purpose of Ohio's juvenile justice system.
We argued that Louisiana’s routine imposition of juvenile life without parole demonstrates the need for a categorical bar on the sentence which disproportionally punishes African-American youth.
We argued that a juvenile's right to due process is violated when he is automatically transferred to the adult system contrary to U.S. and Washington Supreme Court precedent articulating that youth cannot be mandatorily treated as adults.
We argued that Miller and Montgomery establish a presumption against life without parole, which requires a determination that a juvenile has no potential for rehabilitation prior to imposing a life without parole sentence.
The State appealed the trial court’s decision that lifetime registration of an adult for a crime committed as a juvenile is unconstitutional. We argued that the appeal is moot in light of Commonwealth v. Muniz, where the Pennsylvania Supreme Court held retroactive registration under SORNA unconstitutional.
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