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← 879 NW2D 811 - State v. Sweet

State v. Sweet’s Empirical Analysis

2016

Citation profile

21
cited by 21 later decisions
6
states following
December 2019
most recently cited

21 state decisions

Relationships

Relies on Strickland v. Washington · Williams v. Taylor · Gregg v. Georgia · Powell v. State of Alabama Patterson · Furman v. Georgia

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “sentencing courts should not be required to make speculative up-front decisions on juvenile offenders' prospects for rehabilitation because they lack adequate predictive information supporting such a decision. The parole board will be better able to discern whether the offender is irreparably corrupt after time has passed, after opportunities for maturation and rehabilitation have been provided, and after a record of success or failure in the rehabilitative process is available.”
    2 later decisions quote this exact passage · from the concurrence
  2. “[Consideration of] the offender’s family and home environment! ]is ... fraught with risks. For example, what significance should a sentencing court attach to a juvenile offender’s stable home environment? Would the fact that the adolescent offender failed to benefit from a comparatively positive home environment suggest he or she is irreparable and an unlikely candidate for rehabilitation? Or conversely, would the offender’s experience with a stable home environment suggest that his or her character and personality have not been irreparably damaged and prospects for rehabilitation are therefore greater? A similar quandary faces courts sentencing juvenile offenders who have experienced horrendous abuse and neglect or otherwise have been deprived of a stable home environment. Should the offenders’ resulting profound character deficits and deep-seated wounds count against the prospects for rehabilitation and in favor of life-without-the-possibility-of-parole sentences under the Miller framework? Or should sentencing courts view the deprivation of a stable home environment as a contraindication for life without the possibility of parole because only time will tell whether maturation will come with age and treatment in a structured environment?”
    1 later decision quote this exact passage · from the dissent
  3. “[A] categorical rule gives all juvenile nonhomicide offenders a chance to demonstrate maturity and reform. The juvenile should not be deprived of the opportunity to achieve maturity of judgment and self-recognition of human worth and potential. . .. Life in prison without the possibility of parole gives no chance for fulfillment outside prison walls, no chance for reconciliation with society, no hope. Maturity can lead to that considered reflection which is the foundation for remorse, renewal, and rehabilitation. A young person who knows that he or she has no chance to leave prison before life’s end has little incentive to become a responsible individual. In some prisons, moreover, the system itself becomes complicit in the lack of development. ... A categorical rule against life without parole for juvenile nonhomicide offenders avoids the perverse conse quence in which the lack of maturity that led to an offender’s crime is reinforced by the prison term.”
    1 later decision quote this exact passage

How this case has been treated — in progress

Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.