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 how mandatory minimums, sentencing enhancements, and parole practices can combine to impose de facto life sentences on juveniles absent the procedural protections required for imposing an LWOP under Miller. The brief incorporates empirical research on diminished life expectancy for incarcerated people—especially those sentenced as youth—to demonstrate that long mandatory sentences effectively condemn juveniles to die in prison.