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California Supreme Court Restricts Life Without Parole Sentences for Juveniles

California Supreme Court Restricts Life Without Parole Sentences for Juveniles

The California Supreme Court has held that mandatory sentences of life without parole can no longer be applied to juvenile offenders. Even cases involving juveniles convicted of homicide must undergo intense scrutiny before a term of life without parole can be applied.

Handed down on May 5, 2014, the Court consolidated People v. Gutierrez and People v. Moffett, and required trial courts to consider a variety of factors before sentencing a juvenile to life without parole. Based on the U.S. Supreme Court’s decision in Miller v. Alabama,132 S.Ct. 2455, 183 L.Ed. 2d 407 (2012), California’s high court held that trial courts “must consider all relevant evidence bearing on the distinctive attributes discussed in Miller.” See: People v. Gutierrez, 58 Cal. 4th 1354, 324 P.3d 245 (Cal. 2014).

In 2012 the California legislature enacted a statute – California Penal Code § 1170(d) – that allows for reviews of cases in which juveniles were sentenced to life without parole. In opposition to the issues raised in Gutierrez, the Attorney General argued that § 1170(d) had eliminated any constitutional concerns related to sentencing juveniles to life without parole. The state Supreme Court disagreed, holding that scrutiny should be applied before sentencing and not after sentencing.

Human Rights Watch filed an amicus brief in the case citing research that showed considerable differences between juveniles and adults, including that young people don’t act as responsibly as adults and also have a greater capacity to change.

The United States is the only country that allows juveniles to be sentenced to life without parole. The Gutierrez ruling in California, as well as similar rulings in a number of other states, is starting to reverse that trend. [See: PLN, May 2014, p.38].


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Related legal case

People v. Gutierrez