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.