Pennsylvania Supreme Court Significantly Restricts Life Without Parole Sentences for Children


Prosecutors seeking life without parole for juveniles are now required to overcome a presumption against life without parole by proving beyond a reasonable doubt that a child’s rehabilitation is impossible, according to a recent Pennsylvania Supreme Court ruling.

Last week, the Pennsylvania court vacated the life-without-parole sentence of Qu’eed Batts, who was sentenced to die in prison for an offense when he was only 14 years old. In his case, the court unanimously ruled that prosecutors seeking life-without-parole sentences for children must prove beyond a reasonable doubt that a child could never be rehabilitated.

In 2012, the U.S. Supreme Court issued a historic ruling in Miller v. Alabama holding that mandatory life-without-parole sentences for all children 17 or younger convicted of homicide are unconstitutional, and that judges must consider a child’s “diminished culpability and heightened capacity for change.”  In 2016, the U.S. Supreme Court ruled in Montgomery v. Louisiana, that Miller applies retroactively to bar life-without-parole sentences for all but the rare juvenile who “exhibits such irretrievable depravity that rehabilitation is impossible.”

“We conclude that a sentence of life in prison without the possibility of parole for Batts is disproportionate under Miller and Montgomery and thus violates the Eighth Amendment to the United States Constitution,” the justices wrote in the Pennsylvania court ruling.

Pennsylvania joins the growing consensus of state courts taking a realistic approach to constitutional sentences for children by requiring new sentences that provide a meaningful opportunity for release once the child has matured and rehabilitated. Pennsylvania has the highest number of juveniles serving life-without-parole sentences in the country.

The United States is the only country in the world where people are sentenced to die in prison for offenses committed as children. EJI believes that juvenile life-without-parole sentences are unconstitutional and is working to challenge death-in-prison sentences throughout the country.