Read a PDF of our statement here.

The NAACP Legal Defense and Educational Fund, Inc. (LDF) today filed an amicus brief urging the U.S. Supreme Court to take up a case concerning the circumstances under which a juvenile defendant can be sentenced to life in prison without parole. LDF argues that in sentencing a juvenile to life without parole, a Mississippi court ignored clear Supreme Court precedent reserving such sentences for only “the rarest of juvenile offenders” whose crimes suggest they are beyond rehabilitation. If courts fail to adhere to this precedent, children – especially children of color – are at risk of arbitrarily being sent to prison for life.

“The Supreme Court has unequivocally held that juveniles can be sentenced to die in prison in only the rarest of cases,” said LDF Director of Litigation Samuel Spital. “If states ignore this clear precedent, there is a real danger that children will be arbitrarily condemned to live out their days behind bars, a violation of the Eighth Amendment and a stain on our aspirations as a society. What’s more, it is children of color who will bear the brunt of such arbitrariness. The Supreme Court should hear this case and reaffirm its commitment to limiting life-without-parole sentences for juveniles to as few cases as possible.”

The case, Chandler v. Mississippi, concerns the case of Joey Chandler, who committed a murder at age 17. Although his crime undoubtedly warranted a serious penalty, nothing about the circumstances of his crime suggest he was “permanently incorrigible,” the standard set by the Supreme Court in Miller v. Alabama (2012) and reaffirmed in Montgomery v. Louisiana (2016).

After Miller, Mr. Chandler sought a resentencing hearing, which was granted. At this hearing the judge made no effort to assess or consider whether Mr. Chandler was “permanently incorrigible,” ignoring his considerable work towards rehabilitation during his 10-plus years in prison.  

LDF’s brief also notes that without an incorrigibility standard, sentencing judges are more likely to be improperly influenced by conscious or unconscious racial biases against Black defendants like Mr. Chandler. Given the well-documented racial inequalities that plague our justice system – and given widespread stereotypes of Black men as especially prone to violent crime – there is serious risk that Black juveniles would be disproportionately sentenced to life in prison without parole if the incorrigibility standard is not strictly applied.


Founded in 1940, the NAACP Legal Defense and Educational Fund, Inc. (LDF) is the nation’s first civil and human rights law organization and has been completely separate from the National Association for the Advancement of Colored People (NAACP) since 1957—although LDF was originally founded by the NAACP and shares its commitment to equal rights. LDF’s Thurgood Marshall Institute is a multi-disciplinary and collaborative hub within LDF that launches targeted campaigns and undertakes innovative research to shape the civil rights narrative. In media attributions, please refer to us as the NAACP Legal Defense Fund or LDF.