Graham v. Florida (2009)
Question: Does imposition of life without parole for a juvenile convicted of a non-homicidal offense violate the Eighth Amendment?
Holding: Yes; the Eighth Amendment does not permit a juvenile offender to be sentenced to LWOP for a non-homicidal crime. The court must consider objective indicia of society’s standards, and determine whether the punishment violates the Constitution, guided by standards from controlling precedents (e.g., Roper, Atkins).
In re Gault (1967)
Question: Were Gault’s constitutional due process rights (notice of charges, counsel, questioning witnesses, protection against self-incrimination, transcript of the proceedings, and appellate review) denied, given that he was a juvenile?
Holding: Yes; Gault’s commitment to the State Industrial School was a violation of the Fourteenth Amendment due to his being denied the right to an attorney, not being formally notified of the charges against him, not being informed of his right against self-incrimination, and having no opportunity to confront his accusers.
Kent v. US (1966)
Question: What procedural safeguards must be protected for juveniles facing a waiver of jurisdiction to adult court?
Holding: The Court stated, “The right to representation by counsel is not a formality. It is not a grudging gesture to a ritualistic requirement. It is of the essence of justice.” The Court mandated that waivers may only be pursued for juveniles aged sixteen or older, and charged with a felony or any offense punishable by death or life imprisonment for an adult.
Miller v. Alabama (2012)
Question: Does imposition of life without parole for a juvenile violate the Eight and Fourteenth Amendments?
Holding: Yes; children are constitutionally different from adults, for sentencing purposes. While a mandatory life sentence for adults does not violate the Eighth Amendment, that sentence would be disproportionate punishment for children. States are not prohibited from sentencing a juvenile who commits homicide to LWOP, but courts cannot automatically mandate this sentence as this would not allow unique factors of the juvenile to be considered at sentencing.
Ohio v. Aalim (2016; 2017)
Question: Does mandatory transfer of juveniles to the general division of common pleas violate the right to due process under the Ohio Constitution?
Holding: Aalim I found there may be discretionary transfer of juveniles 14 or older, but mandatory transfer violated due process. Aalim II (2017) overturned this; the court stated, “We now recognize that because children are constitutionally required to be treated differently from adults for purposes of sentencing, juvenile procedures themselves also must account for the differences in children versus adults,” and stated mandatory transfer statutes comport with due process and equal protection under both the Ohio and U.S. Constitutions.
Ohio v. Moore (2016)
Question: What are the limits of a prison sentence for a juvenile charged with a non-homicide offense?
Holding: A sentence that exceeds the life of the offender violates the Eighth Amendment.
Parham v. JR (1979)
Question: Is it a violation of due process to voluntarily commit a minor absent an adversarial proceeding?
Holding: The U.S. Supreme Court held that due process does not require that there be a formal or quasi-formal hearing prior to voluntary commitment of a minor. However, the Court made clear that due process does require some kind of inquiry by a neutral factfinder to determine whether a state’s statutory requirements for admission of a minor have been satisfied.
Roper v. Simmons (2005)
Question: Do the Eighth and Fourteenth Amendments prohibit the execution of juvenile offenders?
Holding: Yes; the Court held that the Eighth and Fourteenth Amendments forbid the imposition of the death penalty on offenders who were under the age of 18 when their crimes were committed.