Brief for Amici Curiae Citizens for Juvenile Justice, Committee for Public Counsel Services, Lawyers' Committee for Civil Rights and Economic Justice, Massachusetts Association of Criminal Defense Lawyers, National Association of Criminal Defense Lawyers, National Juvenile Defender Center, and National Juvenile Justice Network in Support of Petitioner (on Petition for Writ of Certiorari).
Argument: The individualized-sentencing requirement for juvenile offenders facing a life sentence protects against unconstitutional sentences. Parole does not resolve the constitutional violation caused by mandatory life sentences for juvenile offenders. Parole boards were originally intended to base release decisions on demonstrated rehabilitation. The modern parole system does not provide a meaningful opportunity for juvenile offenders serving mandatory life sentences to demonstrate rehabilitation.