February 27, 2025
When the Maryland General Assembly passed the Juvenile Restoration Act (JUVRA), it recognized that youth, even those who commit serious crimes, are capable of growth and should have the opportunity to rebuild their lives. Among JUVRA’s provisions, the law allows individuals who have been in prison for at least twenty years for a crime that occurred when they were a minor to petition the circuit court for a reduction of sentence. But Maryland courts have not followed this provision consistently. On January 7, the Public Justice Center and allies filed an amicus brief in Trimble v. State of Maryland, arguing that courts should account for the developmental differences between youth and adults when considering whether to reduce a person’s sentence and urging the Supreme Court of Maryland to vacate a lower court’s denial of a motion for sentence reduction under JUVRA.
In this case, the circuit court refused to reduce Mr. Trimble’s sentence, treating his age—seventeen at the time of the incident—as an aggravating factor, dismissing evidence of his rehabilitation, and relying on diagnosis of a mental health impairment he received when he was eighteen. Even though Mr. Trimble had served forty-one years in prison, earned his GED and bachelor’s degree, held the trusted position of library aide for many years, and maintained a spotless record for more than twenty years, the court gave minimal weight to his evidence of maturity and rehabilitation. The Appellate Court upheld the circuit court’s decision, and the Supreme Court of Maryland agreed to hear the case.
Our amicus brief argues that the lower court’s interpretation undermines the law. Written by Public Justice Center Murnaghan Appellate Advocacy Fellow Sahar Atassi, the brief addresses the scientific consensus that brain development continues into the mid-twenties, emphasizing that courts should never treat a minor’s age as contributing to the need for a more severe sentence. Courts should recognize that adolescents and young adults have trouble gauging risks and consequences and are susceptible to peer pressure, which can contribute to lawbreaking behavior that they will age out of as their brains develop. The brief also demonstrates that his pre-existing diagnosis should not preclude a sentence reduction, particularly given the broadness of the diagnostic criteria and potential for diagnostic inaccuracies associated with the particular impairment, the developmental changes that can occur with age, and the possibility of effective treatment and remission. We hope that the Supreme Court of Maryland will recognize youths’ capacity for growth as an important factor in decisions to reduce sentences later in life.
We are grateful for the support of our co-amici, the American Civil Liberties Union of Maryland, the Baltimore Action Legal Team, and the Campaign for the Fair Sentencing of Youth. Many thanks to PJC paralegals Najá Crockett and Carolina Paul and Office and Operations Manager Sabrina Harris for their assistance with the brief.
