A Project of the University of Michigan Law School and the MDefenders Program

Amicus Brief Arguing De Facto Life Sentences for Juveniles Violate the Eighth Amendment

This amicus brief argues that mandatory term-of-years sentences that deny juvenile offenders a meaningful opportunity for release function as unconstitutional life-without-parole sentences under the Eighth Amendment. Relying on Miller v. Alabama, Graham v. Florida, and Jones v. Mississippi, the brief contends that constitutional analysis must focus on the real-world effect of the imposed sentence rather than the label. It explains […]

Motion to Exclude Ballistics Expert Evidence

This brief follows an extensive Frye hearing on bullet matching evidence and incorporates extensive criticism from the scientific community, an explanation of the unintended impact that a narrow definition of the “relevant scientific community” can have, and evidence of the ways that cognitive bias impermissibly taint pattern-matching evidence.

Motion to Bar Testimony – Shaken Baby Syndrome

Focusing on retinal hemorrhages, this motion cites research showing no proven correlation between shaking and retinal hemorrhage, as well as studies documenting other (non-shaking) causes of retinal hemorrhage.