Motion for Funding for a Juvenile Brain-Development Expert

This motion seeks public funding for a juvenile brain-development expert to explain how developmental immaturity affects a young person’s ability to assess risk, anticipate consequences, and foresee that participation in an underlying felony could result in death. Written in the context of a New York felony-murder prosecution, the motion argues that foreseeability is central to determining whether a death occurred “in furtherance of” the felony and that adolescent neurodevelopment is beyond ordinary jurors’ common knowledge. It relies on research concerning the late development of the prefrontal cortex, heightened reward sensitivity, impulsivity, and the developmental mismatch between cognitive-control and emotional systems. The motion further argues that expert assistance is necessary to protect an indigent client’s due-process, equal-protection, and right-to-present-a-defense interests. An optional section extends the analysis to emerging adults between ages eighteen and twenty-one, whose brains continue developing in areas governing impulse control and risk assessment.