In granting a
successive federal habeas petition last month, the District of Connecticut's Chief Federal
Judge Janet C. Hill has added another important precedent to the mix. (Luis Noel Cruz v. United States, 11-cv-00787-JCH;
United States v. Cruz,
94-cr-00112-JCH-16, Docket Entry 2118 (Amended Judgement).)
Luis Noel
Cruz was 15 years old when he became entangled with the Latin Kings. Five
months after his 18th birthday, Luis carried out orders from above—murdering a
perceived snitch (and a New Haven detective’s son) at point-blank range and chasing
after and holding down another target as a fellow gang member shot him four
times. At age 19, Luis was sentenced to four concurrent life-without-parole
sentences.
On March 15, however,
Chief Judge Hill reduced Luis’s federal sentence to 35 years, offering Luis the
chance the live his final
years as a free man. In doing so, the Court relied upon the important
line of Supreme Court precedent and its progeny handed down since Roper’s 2005 issuance (discussed here),
as well as the critical, defense-offered testimony of Laurence Steinberg—a Temple
University professor and renowned expert on adolescent brain development.
Steinberg’s
research informed the Supreme Court in its own decisions regarding adolescent
brains and criminal justice. Steinberg’s testimony in Luis’s case is a noteworthy
resource for a cogent explanation of the parts of the brain particularly significant
during adolescence—the cognitive control and the limbic systems—and their
impact on youth decision-making. (See
Docket Entry 111, Transcript of 9/26/17 hearing.) Steinberg further attests to why
a bright-line-at-18 can no longer stand given that advancements in research since
2005 demonstrate adolescence in terms of brain development spans into the
mid-20s.
At
a hearing held this February on his federal habeas petition, Luis
testified that he was no longer “that stupid, close-minded kid who hurt so
many with his actions.” His attorney peppered the briefing and verified at the
hearing the “alchemistical transformation” that Luis has made over the past two
decades behind bars.
As
J.D. Salinger captured it, “The mark of the immature man is that he wants to
die nobly for a cause, while the mark of the mature man is that he wants to
live humbly for one.” (The Catcher in the
Rye.)
When
it comes to a young offender, remember to paint the full picture. The fact that youth
matters cannot be overstated.
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