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82 U. Chi. L. Rev. 295 (2015)
Juvenile-Sex-Offender Registration: An Impermissible Life Sentence

handle is hein.journals/uclr82 and id is 301 raw text is: Juvenile-Sex-Offender Registration: An
Impermissible Life Sentence
Robin Walker Sterlingt
In a recent series of cases, the US Supreme Court has recognized that chil-
dren are different from adults, concluding that these differences must inform how
we treat children accused of serious crimes. If children are different when they
are charged with homicide and face a possible sentence of life without parole, they
are also different when they are charged with sex offenses and face the possibility
of mandatory lifetime sex-offender registration. The same principles that have led
the Court to categorically exempt youths from the death penalty, life without parole
for nonhomicide crimes, and mandatory life-without-parole sentences should lead
to the abolition of mandatory lifetime juvenile-sex-offender registration. This Essay
argues that the Court's reasoning and analysis in recent juvenile-justice cases indi-
cate that mandatory lifetime juvenile-sex-offender registration is ripe for successful
challenge.
INTRODUCTION
The last decade has seen unprecedented advances in juvenile-
justice jurisprudence. In the 2005 case Roper v Simmons,1 the
Supreme Court held that the federal Constitution categorically
prohibits death sentences for all juvenile offenders convicted of
capital crimes.2 Five years later, in Graham v Florida,3 the
Court held that the Constitution categorically prohibits sentenc-
es of life in prison without the possibility of parole for juvenile
offenders convicted of nonhomicide offenses.4 In 2011 in J.D.B. v
North Carolina,5 the Court held under Miranda v Arizona6 that
t Assistant Professor, University of Denver Sturm College of Law. I would like to
extend my sincerest thanks to the editors, as well as Professors Richard Epstein,
Richard McAdams, and Alison Siegler for inviting me to participate in this symposium. I
am particularly indebted to Professors Patience Crowder, Christopher Lasch, Nantiya
Ruan, and Catherine Smith for their thoughts on this Essay. John Chase and Amelia
Power provided excellent research assistance.
1 543 US 551 (2005).
2 Id at 570-71.
3 560 US 48 (2010).
4 Id at 74.
5 131 S Ct 2394 (2011).
6 384 US 436 (1966).

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