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Running Header: Life Sentences as Juvenile Justice
Michael Dunn
CCJS 100 7380
Introduction to Criminal Justice (2165)
An Application of the Criminal Justice System
Life Sentences as Juvenile Justice
07 August, 2016

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Life Sentences as Juvenile Justice 2
As of 2012, there were 159,520 people serving life sentences in America. (The
Sentencing Project, 2013) Of those serving these sentences, approximately 2,500 of those
offenders were or are still juveniles. (Rovner, 2016) There are currently approximately 200
inmates serving life sentences, with the possibility of parole, for sentences committed while a
juvenile. Maryland is one of only three states where the governor must approve parole for life
sentence prisoners. Following the U.S. Supreme Court ruling in the case of Miller v. Alabama,
states now have to consider circumstances connected to each juvenile defendant in determining
sentencing. This ruling played a major part in the sentencing of then 17-year-old Latray Hughes.
On October 29 2014, around 11 p.m. police responded to a shooting when they found 25-year-
old Barquese Warren who had been shot, the victim of a break in. He was pronounced dead on
the scene. Investigators later went on to discover Warren had been shot six times while lying in
bed watching television by then 16-year-old Latray Hughes. In court filings, the prosecution
noted the break in was the result of an earlier argument over stolen clothes involving Warren’s
sister. While Warren wasn’t actually a part of the dispute, he was in the home when Hughes and
two other assailants broke into the home.
During the case, prosecutor Bill Bickel stated that he felt a life sentence was appropriate
considering Hughes had received substantive rehabilitative treatment from the state as part of a
long troubling past. Hughes’ lawyers painted the picture in court of an extremely troubled,
unstable life, filled with family issues and dysfunction. This picture included a history of
witnessed violence at an early age, even being a witness to shootings on three or four separate
occasions while growing up in West Baltimore.

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Life Sentences as Juvenile Justice 3
The teen, being abandoned by his father and losing his mother to incarceration as a toddler had a
rough start indeed. Hughes even began using marijuana at the tender age of 9 years old, and was
enrolled into Baltimore Community High School as a special education student; as an 11th grader
Hughes could only read at a sixth-grade level, do fourth grade level math, and write at the
seventh-grade level. (Knezevich, 2016)
According to investigators, the suspect entered the home with two additional persons. While in
the home, there was an altercation with the victim, at which the suspect then shot the victim.
During the investigation, it was reported that the break in stemmed from a disagreement over
stolen clothes involving a woman named Chadon Bradshaw and Warren’s sister. Three suspects
entered the home while Bradshaw waited in the car. All three suspects were apprehended and
charged with first degree murder. The three suspects were James Murphy (23), Delonte Epps
(23), and Latray Hughes (16).
The court proceedings were held in a Baltimore County Circuit court, where Hughes was
represented by public defender James Johnston. Ruling over the proceedings was Circuit Judge
Ruth Jakubowski, and trying the case for the state of Maryland was Bill Bickel. The case
received testimony from Chadon Bradshaw, who went to Warren’s home with the suspects but
remained in the car, Warren’s sister, his uncle, and his mother who said “All the way around, it’s
terrible,” and “I do care because I’m a mother and he’s a child.” (Knezevich, 2016)

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Life Sentences as Juvenile Justice 4
Bradshaw agreed to a plea deal in exchange for her testimony. She received a 15-year sentence
for second degree murder and burglary. Hughes’ lawyers used his troubled past, and unstable
upbringing as their defense, but it wasn’t enough to keep their client from being found guilty of
first degree murder as the triggerman.
The sentence itself seemed fare to many considering the crime. However, it’s believed to be the
first time a juvenile was sentenced to life in prison since the controversial decision by the U.S.
Supreme Court that life sentences for juveniles should be looked at much more careful. Though
Hughes’ sentence is parole eligible, the defense for Hughes argued in court to have a jury
selected to determine their client’s sentence; arguing that “In Maryland, life means life.” The
defense believed that a life sentence in Maryland would in fact be a life without parole sentence,
because there has only been one life sentence offender paroled since the early 1990s
Johnston went on the say “Because this is an enhanced penalty, we believe a defendant has a
federal constitutional right to a jury determination on this issue.” (2016) Judge Jakubowski didn’t
agree with the defense and denied their motion to have a jury determine the sentence, and the life
sentence was handed down. The defense took a great gamble in requesting a jury sentence as it is
possible that a life without parole sentence would’ve been handed down.
Latray Hughes is currently serving out his sentence in the North Branch Correctional Institution
in Cumberland, MD, where he will be housed for the remainder of his life unless parole is
granted by the governor of the state.

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Life Sentences as Juvenile Justice 5
The Hughes case is said to have been the first juvenile case where the defendant was sentenced
to life in prison since the U.S. Supreme Court determined that cases of this nature should be
handled carefully and closely. (Knezevich, 2016) Though the Eighth Amendment of the U.S.
Constitution bans cruel and unusual punishment; the case of Weems v. U.S., 1910 deemed that
“punishment for crime should be graduated and proportioned to the offense. Even though the
juvenile suspect was being tried as an adult for first degree murder, careful consideration was
still being given. Such as the case of Kennedy v. Louisiana, 2008, this had the Supreme Court
determining that capital punishment is disproportionate for a category of non-homicide offenses.
Caldwell notes that “what began as an exception, carved out for the “worst of the worst”
expanded to have a broad reach.” (2010)
Since the case of Latray Hughes, the ACLU has filed a lawsuit in the U.S. District Court in
Baltimore claiming that sentencing juveniles to life in prison in Maryland is unconstitutional
because it leaves them with no meaningful chance at parole. Also claiming that “Maryland has
denied any hope of release to juvenile lifers who have matured and done everything they could to
reform and show they have been rehabilitated. (Linderman, 2016)
The Hughes case is an example of the failures of the American criminal justice system to
rehabilitate a juvenile in their early years, and the risk for graduated behaviors as the individual
ages. In the case of Hughes, the prosecution argued that the state had done everything in its
power to rehabilitate the accused with no luck of bettering his behavior. This may be a testament
to the failures of a system, or the possibility that some people are born criminals.

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Life Sentences as Juvenile Justice 6
The murder of Barquese Warren is unfortunately a crime that is all too familiar in West
Baltimore. The senseless acts of violence with seemingly no consideration for life is troubling at
best, but continues to happen even still. What surprises most is when these heinous crimes are
committed by those look at as innocent, frail, and sensitive. The Justice Policy Institute reports
the United States has six times as many juveniles in the prison system as all other comparison
nations combined. (2011)
When Latray Hughes was sentenced to life in prison, the sentence was handed down with
consideration for his upbringing, mental state, education, and juvenile service record. Though the
A.C.L.U. continues to fight juvenile life sentences in Maryland claiming a life sentence is
virtually a death sentence, one could make the case that Hughes’ punishment is fitting the crime
he committed. The history of violent behavior which left a trail of victims may have weighed
much heavier than the fact that the defendant was a juvenile. There’s a long road ahead for
Hughes even though he is eligible for parole, as there has only been one out of the 2000 parole
eligible life sentence serving offenders in the state of Maryland since the early 1990’s.
Though the criminal justice system is ever evolving, the state of Maryland has a long way to go
as it relates to how they sentence juveniles.

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Life Sentences as Juvenile Justice 7
References
Caldwell, B. (2014). GLOBALIZATION AND JUVENILE LIFE SENTENCES: CREATING
MEANINGFUL OPPORTUNITIES FOR RELEASE FOR JUVENILE OFFENDERS. The
Journal of the Institute of Justice & International Studies, 1-9.
et. al, Criminal Law - Juvenile Life Without Parole Sentences. (2014). Harvard Law Review,
127(1252), 1252-1259. Doi:10.1037/e540732012-010
Greene, E., & Evelo, A. J. (2013). Attitudes regarding life sentences for juvenile offenders. Law
and Human Behavior, 37(4), 276-289. Doi:10.1037/lhb0000031
Knezevich, A. (2016, March 21). Teen sentenced to life in Dundalk murder amid debate over
juvenile sentencing. Retrieved August 01, 2016, from
http://www.baltimoresun.com/news/maryland/crime/bs-md-juvenile-life-sentence-appeal-
20160321-story.html
Linderman, J. (2016, April 06). ACLU Suit: 'Unconstitutional' For Maryland to Sentence
Juveniles to Life in Prison. Retrieved August 01, 2016, from
http://talkingpointsmemo.com/news/aclu-lawsuit-mayland-life-sentences-juveniles-
unconstitutional
Nellis A. Ph.D., (2013). Life Goes On: The Historic Rise in Life Sentences in America. Research
and Advocacy for Reform, The Sentencing Project, 1-4.
Rovner, J. (2016, July 01). Juvenile Life Without Parole: An Overview | The Sentencing Project.
Retrieved August 05, 2016, from http://www.sentencingproject.org/publications/juvenile-life-
without-parole/