California Court of Appeals Affirms Life Without Parole Sentence for Young Adult Offender

California Second District Court of Appeal (link)

On January 29, 2021, a California court of appeals affirmed Eric Scott Joseph’s sentence to life without the possibility of parole (LWOP) and denied his petition for a youth offender parole hearing.

In July 1986, at the age of 20, Joseph was convicted of first-degree murder committed in the commission of a robbery and sentenced to LWOP. In 2019, he petitioned for a youth offender parole hearing under a California statute that affords parole hearings to juvenile offenders serving LWOP sentences and young adult (18–21 year old) offenders serving lengthy but non-LWOP sentences.

Recognizing that he did not fall under either category, Joseph argued that his exclusion from the statute violated his constitutional right to equal protection. He contended that he was similarly situated to young adults serving non-LWOP sentences and to all juvenile offenders given current knowledge of brain development. Differentiating young adults serving LWOP sentences from these groups, he argued, was not rationally related to a legitimate government interest.

The court of appeals acknowledged that young adults are not fully mature and therefore have a lower degree of culpability and increased likelihood of rehabilitation, but nevertheless found that the Legislature had significant rational basis to treat young adults sentenced to LWOP differently than young adult non-LWOP offenders and youth offenders.

LWOP sentences, the court noted, are reserved for crimes deemed “so morally depraved and so injurious as to warrant a sentence that carries no hope for release.” The Legislature therefore could have rationally concluded that young adults who commit these offenses are more culpable despite not being fully mature.

Similarly, the Legislature could have rationally concluded that young adults’ older age at the time of their offenses made them more dangerous than minors convicted of the same crimes. The court accordingly denied Joseph’s petition for a youth offender hearing and affirmed his sentence.

Citation: People v. Joseph, 2021 WL 302612 (Cal.App. 2 Dist., 2021).

Key Words: California, LWOP, young adult, juvenile, equal protection, youth offender

This post is the 97th post as part of an ongoing Center for Law, Brain & Behavior (CLBB) series tracking the latest developments in law and neuroscience cases. To see previous posts about recent cases, see the full case archive on the CLBB website. To see updates on legal scholarship, see the Neurolaw News, hosted by the MacArthur Foundation Research Network on Law and Neuroscience. This project is made possible through support of the Dana Foundation.

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at Mass General Hospital, Harvard Medical School

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