Fourth Circuit Ruling Supports Challenge to Parole System for Juvenile Offenders

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In an important decision protecting the constitutional rights of juvenile offenders, the Fourth Circuit Court of Appeals dismissed the State’s appeal in Hayden v. Butler. In September 2015, the U.S. District Court for the Eastern District of North Carolina declared the State’s parole process for juvenile offenders unconstitutional, and ordered the State to reform the system. The State appealed that decision, and the Center for Civil Rights and the UNC Youth Justice Clinic filed an amicus brief in support of Shaun Hayden, who is represented by North Carolina Prisoner Legal Services.

Acknowledging that the State’s parole system—which among other deficiencies fails to even identify whether a parole candidate is a juvenile offender—fails to meet the constitutional guarantees the United States Supreme Court recognized in Graham v. Florida, the District Court’s opinion gave the parties 60 days to present a plan “to provide a meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation to juvenile offenders convicted as adults.”

The Fourth Circuit held that the lower court’s order to develop a plan is not a final order or otherwise immediately appealable. Additionally, because the lower court retained jurisdiction over Hayden’s request for injunctive relief, the appellate court had no jurisdiction over the case and dismissed the State’s appeal.

The parties will now work to fulfill the District Court order and develop a parole plan for juvenile offenders that comports with controlling constitutional precedents, which require particular consideration of the unique characteristics of youth, including lessened culpability and a greater capacity for change.

The Center and Youth Justice Clinic’s amicus brief also examined the racially disparate impacts of North Carolina’s parole system, highlighting that 73% of the 172 North Carolina inmates currently serving life sentences for crimes they committed as children are African American.


Posted by Mark Dorosin on Tue. August 2, 2016 12:03 PM
Categories: Criminal Justice
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