State v. Ryan, 249 N.J. 581 (2022)


Dillon J. McGuire appeared before the New Jersey Supreme Court on behalf of amicus curiae ACDL-NJ, arguing that a prior criminal offense committed by a juvenile should not be used as a predicate offense to justify a life sentence without parole under the “Three Strikes Law” N.J.S.A. 2C:43-7.1. The Court disagreed, ruling that juvenile convictions in adult court could, in fact, serve as predicate offenses under the Three Strikes Law. In his dissent, Justice Albin supported our position, observing that “Comer and Zarate established that culpability for juvenile crimes and adult crimes cannot be weighed on the same scale because of the distinguishing characteristics of youth, such as immaturity and impetuosity, and because the juvenile brain is not fully developed. On that basis, giving the defendant’s juvenile conviction the same constitutional weight as his adult convictions under the Three Strikes Law is at odds with the evolving standards of decency addressed in our federal and state constitutional caselaw.”

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