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Adolfo Davis Re-Sentenced to Life in Prison for a Crime He Committed at Age 14

On May 4, 2015, Cook County Judge Angela Petrone resentenced Adolfo Davis to life in prison for a crime he committed when he was 14 years old. In its landmark 2012 decision in Miller v. Alabama,[1] the United States Supreme Court decided that mandatory life without parole sentences for young people under 18 convicted of homicide are unconstitutional and constitute “cruel and unusual” punishment. While juveniles can still be sentenced to life without parole, the Miller Court once again recognized that juveniles have lessened culpability and a greater capacity for change than do adults. The Court determined that judges must weigh certain criteria in deciding the sentence, such as the offender’s chronological age, maturity, ability to understand risks and consequences, and family history. Despite these criteria, the court resentenced Adolfo to natural life in prison, stating that his resentencing “is necessary to deter others. It is necessary to protect the public from harm…[because his] acts showed an aggression and callous disregard for human life far beyond his tender age of 14.”[2]

The Court’s decision completely went against the spirit of Miller. It should not have focused on the severity of the charged crime. The judge assigned no weight to his history of trauma, abuse, and neglect or the ways in which he turned his life around after being incarcerated. In stating that his “commendable acts towards self-improvement and the support he has received from well-meaning but uninformed persons, are not sufficient for this court to alter his sentence,”[3] the judge clearly misinterpreted the holding and reasoning in Miller.

For the past three years, advocates around the country have been filing retroactive petitions for resentencing of inmates who were sentenced to mandatory life without parole sentences for crimes committed before the age of 18. In 2013, Adolfo’s attorneys successfully petitioned the Illinois Appellate Court for resentencing. The State appealed the case to the Illinois Supreme Court, which, in March of 2014, unanimously found that the Miller ruling applies retroactively. Adolfo’s resentencing hearing occurred in April of this year.

Despite mounting evidence that long sentences do not serve as a deterrent to committing crimes and research and court decisions affirming that common sense notion that youth should not be held to the same standards as adults, Adolfo, now 38, will remain in prison for a crime he committed twenty-four years ago. In resentencing him, the court decided that his young age, his history of poverty and neglect, and his minor role in the offense should not be taken into account. Though Adolfo has earned a GED and mentors youth to keep them from committing crimes while in prison, the court believes that keeping him in prison for life “protects the public from harm.” The Miller ruling affirmed that courts should start looking at juvenile who commit crimes differently, but Adolfo’s resentencing shows that judges and prosecutors still need training and guidance on how to apply research on adolescent development in individual cases. Adolfo’s defense team is led by Patricia Soung of Loyola Law School’s Center for Juvenile Law & Policy. Soung, who worked on the case as a NCYL staff attorney, says she plans to appeal the decision.

[1] Miller v. Alabama, 132 S. Ct. 2455 (2012) (consolidated with Jackson v. Hobbs, No. 10-9647).

[2] Ranjani Chakraborty, Imprisoned at 14, Illinois Inmate Gets Resentenced to Life Without Parole, AlJazeera America, May 4, 2015, available at:

[3] Convicted Murderer Adolfo Davis Re-Sentenced to Life in Prison, May 4, 2015, available at: