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50-state examination

The AP spent months reviewing how counties and states are wrestling with re-examining juvenile life without parole. While some have resentenced and released juvenile lifers locked up for years, others have resisted taking action as battles continue in legislatures and courts.

Alabama has 72 inmates.

RESENTENCED OR RELEASED  
At least 20 inmates have been resentenced to parole-eligible sentences. One has gone before the parole board, but was denied release.

LAW 
Lawmakers in 2016 passed a measure that allows juveniles convicted of capital murder life with the possibility of parole after 30 years, but life without parole remains an option.

State story

Alaska has no inmates.

LAW 
The state does not have a juvenile life-without-parole sentence.

State story

Arizona has 34 inmates.

RESENTENCED OR RELEASED  
One so far. Jack David Jewitt was resentenced in June and is eligible for parole in 2021, after serving 28 years in prison. He was 14 when he and a then-20-year-old accomplice carjacked and fatally shot a woman. Jewitt’s accomplice committed the murder. A handful of other inmates have petitioned for new sentences.

LAW 
Life without parole for juveniles has always been discretionary in Arizona. Nevertheless, prosecutors are reviewing juvenile lifer cases and lawyers predict lower-court judges will hold resentencing hearings to determine who should get a new term.

State story

Arkansas has 114 inmates.

RESENTENCED OR RELEASED  
At least 16 resentenced, and 11 of those have been released

LAW 
A state law that took effect in March banned life without parole for juvenile offenders and makes those already serving the sentence eligible for release after serving 25 years for first-degree murder or 30 years for capital murder.

State story

California has 268-283 inmates.

RESENTENCED OR RELEASED  
Corrections officials could not say how many have been resentenced, but Human Rights Watch estimates about 50 juvenile lifers have had their sentences reduced and seven have been released.

LAW 
A 2012 state law allows those sentenced to life without parole as juveniles to petition for resentencing. A judge can grant a hearing, and has the discretion to lower the penalty to 25-to-life.

State story

Colorado has 48 inmates.

RESENTENCED OR RELEASED  
At least four resentenced; one released. The state Department of Corrections said several others are potentially coming up for resentencing soon.

LAW 
Colorado lawmakers in 2016 ordered corrections officials to create a program for offenders sentenced to life terms as juveniles, with or without parole. Those inmates could join the program after serving 20 years or 25 years if they were convicted of first-degree murder.

State story

Connecticut has 66 inmates.

RESENTENCED OR RELEASED  
All are still incarcerated except for one, who died this year. But the state is in the process of so-called “juvenile reconsideration hearings,” a new parole eligibility system for juvenile offenders who got more than 10 years in prison.

LAW 
A 2015 state law effectively abolished even lengthy sentences for offenders under the age of 18. It requires the state take a

State story

Delaware has 1 inmate.

RESENTENCED OR RELEASED  
Before the 2012 U.S. Supreme Court ruling on juvenile life without parole, 14 juvenile offenders had been serving life without parole. All were resentenced from November 2013 to April 2016. Five have been released.

LAW 
Lawmakers revised Delaware’s sentencing laws in 2013, mandating a minimum sentence of 25 years for anyone convicted of first-degree murder for an offense committed as a juvenile. Life without parole remains an option for juveniles, but they are entitled to petition for a review of their sentence after serving 30 years.

Florida has about 600 inmates.

RESENTENCED OR RELEASED  
Florida no longer has parole, so addressing these cases has been tricky.

LAW 
In 2014, legislators changed the law to give juveniles, including those serving life sentences, an opportunity to have their sentences automatically reviewed by a judge after 15, 20 or 25 years served, depending on the crime.

State story

Georgia has 25 inmates.

RESENTENCED OR RELEASED  
Experts are aware of only one resentencing case. The Georgia Supreme Court vacated the no-parole sentence of a man convicted for murder, rape, armed robbery and other charges at 17, emphasizing that such sentences should be permitted for only the “rarest of juvenile offenders.”

LAW 
Georgia law requires that inmates given life sentences for violent felonies serve at least 30 years before becoming eligible for parole, including juveniles sentenced as adults.

State story

Hawaii has no inmates.

LAW 
In 2014, lawmakers approved a measure that excludes life without parole for those 17 and younger.

State story

Idaho has 4 inmates.

LAW 
Life without parole is allowed but not required for any crimes committed by juveniles.

State story

Illinois has 80 inmates serving mandatory life without parole for juvenile offenses, and another 20 who received discretionary life-without-parole sentences for offenses committed as juveniles.

RESENTENCED OR RELEASED  
About 35 of the 80 mandatory juvenile lifers have been resentenced, according to Shobha Mahadev, assistant law professor at Northwestern University and project director of the Illinois Coalition for the Fair Sentencing of Children.

LAW 
In the last three years, laws have been enacted that give judges broader discretion in handling cases involving juveniles. The age of juvenile court jurisdiction for most crimes has been raised to those 17 and younger _ it previously was 16 and younger. Also, there’s now a more limited range of crimes automatically transferred to adult court.

State story

Indiana has five men are serving life-without-parole sentences for murders committed when they were juveniles, according to the Indiana Public Defender Council.

LAW 
Indiana law allows judges to use their discretion and sentence those convicted of committing murder when they were over the age of 16 to life without parole.

State story

Iowa originally had 46 juvenile lifers.

RESENTENCED OR RELEASED  
Of the 46, all but three have been resentenced with the possibility of parole, according to the Iowa Department of Corrections.

LAW 
In 2016, the Iowa Supreme Court voted 4-3 that juvenile life-without-parole sentences are unconstitutional. In a case in June, the court said that even mandatory minimum sentences should be uncommon for juveniles.

State story

Kansas has no inmates.

LAW 
Offenders under 18 are prohibited from receiving life without parole.

State story

Kentucky has 4 inmates.

RESENTENCED OR RELEASED  
All of the inmates have filed legal challenges asking to be made eligible for parole. A spokeswoman for the state attorney general’s office said the U.S. Supreme Court’s ruling last year that applied its ban on juvenile life without parole retroactively does not apply to any of the defendants.

LAW 
State law does not provide for any life-without-parole sentences for juveniles. The state Supreme Court banned such sentences for juveniles charged with homicide in 2008.

State story

Louisiana has 303 inmates.

RESENTENCED OR RELEASED  
The agency does not track resentencings. But over the last year, at least 67 inmates have been resentenced to life in prison with the possibility of parole, according to the Louisiana Center for Children’s Rights. A small number of juvenile lifers have been resentenced to life without parole. Since the start of 2016, four juvenile life inmates have been released.

LAW 
Legislation that takes effect in August makes juvenile lifers eligible for parole after serving 25 years, although prosecutors can still petition judges for no-parole sentences.

State story

Maine has no inmates.

LAW 
Only a juvenile tried as an adult can receive a life sentence. Maine eliminated parole more than 40 years ago, so all life sentences are imposed without the possibility of parole. But the attorney general’s office says it’s not aware of any cases where a juvenile has been bound over and sentenced to life.

State story

Maryland has about 12 inmates.

RESENTENCED OR RELEASED  
Four of the 12 had their sentences vacated and await resentencing. A larger group, totaling 271, is serving life with the possibility of parole for offenses committed as juveniles, according to the Maryland Department of Public Safety and Correctional Services.

LAW 
Juveniles can still get life without parole for homicide, but judges can use their discretion to suspend any number of years off the term. In cases involving juveniles, judges are required to consider a number of factors including age and whether the crime reflects transient immaturity or irreparable corruption.

Massachusetts has 63 inmates.

RESENTENCED OR RELEASED  
Of the 63, 10 have been paroled. Another was released after pleading guilty to manslaughter when granted a new trial. Twenty others have been denied parole during hearings that have been underway for about three years. The remaining are either awaiting hearings, have asked to postpone their hearings or have a date at which they will be released, if they meet certain requirements.

LAW 
In 2014, Massachusetts law established a three-tier system of parole eligibility for juveniles convicted of first-degree murder. Under the measure, they are eligible for parole in 20 to 30 years, depending on the specifics of the crime.

State story

Michigan has 363 inmates.

RESENTENCED OR RELEASED  
About 86 juvenile lifers have been sentenced to a term of years, 47 of whom became immediately eligible for parole, according to defense lawyer Deb LaBelle. Twenty-two have been released.

LAW 
After the 2012 ban on mandatory life without parole for juveniles, state lawmakers passed a measure that said if the ruling became retroactive and if the prosecutor didn't seek a no-parole term within a certain amount of time, the inmates must be resentenced to a minimum 25 to 40 years and a maximum of 60 years. The 2016 decision by the nation's highest court to apply the ban retroactively led to the resentencings, which began last September.

State story

Minnesota has 8 inmates.

RESENTENCED OR RELEASED  
Seven of the eight were resentenced to life with the possibility of parole after 30 years. The final inmate still awaits resentencing.

LAW 
State law has not been changed to ban mandatory life-without-parole sentences for juveniles, but a state Supreme Court ruling means most of those resentenced will be eligible for parole after 30 years. The state is still wrestling with how to handle offenders who killed multiple victims as teenagers and are serving more than one life sentence.

State story

Mississippi has 87 inmates.

RESENTENCED OR RELEASED  
Of those, about 50 await resentencing, 28 got new sentences that now have the possibility of parole and seven others were resentenced to natural life, according to Andre’ de Gruy, state public defender. One inmate died before resentencing.

LAW 
A case that awaits consideration in the state Court of Appeals could eventually provide a consistent answer on how these matters should be handled and whether judges or juries should impose new sentences. Presently, juvenile lifers and others in the state can seek parole after serving 10 years.

State story

Missouri has 94 inmates.

RESENTENCED OR RELEASED  
A state law passed in 2016 allows those inmates to argue for parole after serving 25 years. Since last fall, 20 of 23 juvenile lifers who have sought release have been denied, according the MacArthur Justice Center.

LAW 
A 2016 law provides a range of terms for juveniles convicted of first-degree murder.

State story

Montana has 2 inmates.

RESENTENCED OR RELEASED  
One, serving a 100-year sentence for a fatal beating, is asking for the state Supreme Court to order parole eligibility or a new sentencing hearing to comply with U.S. Supreme Court rulings. Attorneys for the other inmate, sentenced to three consecutive life terms without the possibility of parole for killing a family during a robbery, have moved to stay his appeal until the other case is decided.

LAW 
In 2007, the state abolished life-without-parole sentences for juvenile offenders. However, judges have discretion to suspend parole-eligible sentences and make offenders serve out their terms, but that has never happened in the case of a juvenile offender, according to the Campaign for the Fair Sentencing of Youth.

State story

Nebraska has 22 inmates.

RESENTENCED OR RELEASED  
All but three of the 22 have been resentenced, several to de facto life sentences of 70 to 90 years. Some inmates who received those lengthy sentences challenged them, but their appeals were rejected by the Nebraska Supreme Court. Five other juvenile lifers have been released.

LAW 
A law was passed in 2013 imposing 40 year to life sentences for the most serious crimes for juveniles, who are eligible for parole after serving half of their minimum sentence. The measure requires the sentencing judges to consider several factors, including age and intellectual capacity. It also requires the state parole board to review these inmates’ cases once a year after they begin serving their sentences and consider similar mitigating factors.

State story

Nevada has 19 inmates who were sentenced to death or life without parole for crimes committed at 17 or younger remain in prison.

RESENTENCED OR RELEASED  
A state law that went into effect in October 2015 made 24 Nevada inmates eligible for parole hearings if they were juveniles at the time of the crime, had not been convicted of multiple murders and had already served 20 years in prison, said Kristina Wildeveld, a Las Vegas lawyer. Five were granted parole. One inmate was resentenced to life in prison without parole.

LAW 
The 2015 law banned life without parole for juveniles in the state and provides parole eligibility after 15 or 20 years served, depending on the crime.

State story

New Hampshire has five inmates who had life-without-parole sentences for crimes committed when they were 17.

RESENTENCED OR RELEASED  
Of the five, one was resentenced to life without parole. He refused to attend his hearing and didn't authorize his lawyers to argue for a lesser sentence. Hearings have been scheduled for two of the others. The other two haven’t been scheduled.

LAW 
There have been no changes to New Hampshire law regarding juvenile offenders following the Supreme Court rulings. Juveniles can still be certified to stand trial as adults, but they will no longer automatically be sentenced to life without parole for crimes that carry that sentence.

State story

It's unclear how many inmates New Jersey has.

INMATES 
Unclear. Juveniles who are tried and convicted in adult court can be sentenced to life without parole, but the state Department of Corrections says it doesn’t keep records of how many inmates, if any, are serving that sentence.

LAW 
In January, the state Supreme Court ordered new sentences be granted to two inmates serving de facto life terms for crimes committed when they were under 18. On July 21, Gov. Chris Christie signed into law a measure prohibiting mandatory life without parole for juveniles and making them eligible for parole after 30 years.

State story

New Mexico has no inmates.

LAW 
Judges in the state have broad authority to decide whether to sentence youth convicted of serious crimes as juveniles or adults.

State story

New York has no inmates, according to the state corrections department.

LAW 
Life without parole is only a sentencing option for juveniles convicted of the crime of terrorism in New York state, though no juvenile has ever been convicted of that crime. The New York Board of Parole is now reviewing its procedures to ensure an offender’s youth at the time of the crime is properly considered in parole decisions in the wake of federal and state rulings that youthful offenders must have a meaningful chance at parole.

State story

North Carolina has 93 inmates originally serving life without parole for juvenile crimes.

RESENTENCED OR RELEASED  
Of the 93, 30 have been resentenced. Of those, six received new life-without-parole sentences and the other 24 will be eligible for release at some point, according to Ben Finholt, staff attorney at the North Carolina Prisoner Legal Services.

LAW 
Before the Supreme Court ruling in 2012, any juvenile convicted of first-degree murder was automatically sentenced to life without parole. That same year, the state law was changed so any of these offenders serving that sentence or convicted of first-degree murder must receive a sentencing hearing. Inmates may be made eligible for parole after 25 years.

State story

North Dakota has one inmate is serving life without parole for a fatal shooting committed at 17.

RESENTENCED OR RELEASED  
A Fargo judge in January rejected the inmate’s petition for a new sentence.

LAW 
In April, the governor signed into law a measure banning life-without-parole sentences for juveniles. The law also allows offenders under the age of 18 who were convicted of serious crimes to seek judicial review to demonstrate they're deserving of a second chance after they've served 20 years.

State story

Ohio has eight inmates serving life sentences without parole for homicides they committed or were involved in when they were under 18, according to state prison records. Several more are serving de facto life sentences, terms so long they amount to life behind bars.

RESENTENCED OR RELEASED  
Some of the eight have appeals pending on various aspects of their cases. One offender, Devonere Simmonds, argues that his age entitles him to a sentencing hearing similar to what death penalty defendants receive, where inmates can present evidence.

LAW 
Juveniles can still get life without parole for aggravated murder if they're first bound over to adult court.

State story

Oklahoma has at least 41 inmates serving life-without-parole sentences for crimes committed while they were juveniles.

RESENTENCED OR RELEASED  
None so far, though two cases have been remanded to district court for resentencing. There is no specific review process to deal with these cases. In Oklahoma County, the state’s largest, a handful of resentencing motions have been filed, and prosecutor Scott Rowland said the office would address each on a case-by-case basis.

LAW 
The Oklahoma Court of Criminal Appeals spelled out new sentencing guidelines late last year when it tossed the life-without-parole sentence of Chancey Luna, who was 16 when he fatally shot Christopher Lane, a college baseball player from Australia. The court developed new instructions for juries to consider before imposing a no-parole sentence on minors, and said the sentence is prohibited unless “you find beyond a reasonable doubt that the defendant is irreparably corrupt and permanently incorrigible.”

State story

Oregon has five inmates serving life without parole for murders they committed between the ages of 15 and 17.

INMATES  
These sentences have always been discretionary. Another seven men who committed crimes as juveniles are serving de facto life sentences because they’re not eligible for release until they’re over 65.

RESENTENCED OR RELEASED  
Since the Supreme Court decisions, Oregon has resentenced one inmate, who got a new life sentence, with eligibilty for parole after 30 years.

LAW 
Life without parole is discretionary in the state. A jury decides whether to impose the penalty, but a defendant can waive that right and ask a judge to rule.

State story

Pennsylvania has 517 inmates serving mandatory life without parole for crimes committed as juveniles at the time of the January 2016 Supreme Court decision.

RESENTENCED OR RELEASED  
116 have been resentenced as of July 25, including two who again got life without parole, according to corrections officials. So far at least 58 have been released, and five others were denied parole. Three others died in prison.

LAW 
After the Supreme Court banned mandatory life terms for juveniles in 2012, Pennsylvania's highest court ruled the decision did not apply to inmates already serving such sentences. That year, state lawmakers approved new sentences for juvenile killers of 20-35 years before parole eligibility, depending on the crime and age of the offender, but life without parole was still an option.

State story

Rhode Island has no inmates. The state has never sought a life-without-parole sentence for a juvenile.

LAW 
The Senate voted 28-8 this year to pass legislation that would effectively eliminate life without parole for juveniles, but the measure did not pass the House. State Attorney General Peter Kilmartin has said prosecutors shouldn't be precluded from seeking a life sentence without parole for a juvenile who commits an

State story

South Carolina has 38 inmates who had juvenile life-without-parole sentences.

RESENTENCED OR RELEASED  
Of the 38, three had death sentences reduced after the U.S. Supreme Court banned capital punishment for juvenile offenders. Three others have now been resentenced to new terms that range from 30 to 40 years; a fourth is awaiting resentencing.

LAW 
In 2014, the South Carolina Supreme Court ruled that life without parole is unconstitutional for juveniles, ordering that such inmates could request resentencing.

State story

South Dakota has three inmates who had life without parole sentences.

RESENTENCED OR RELEASED  
All have been resentenced, and one is eligible for parole next year. The two others were 14 when they committed murder; one received two concurrent 200-year sentences, the other a 92-year sentence. Both challenged the sentences, which were upheld by the South Dakota Supreme Court. Both, however, will be eligible for parole.

LAW 
Last year, the state abolished life in prison for those under the age of 18.

State story

Tennessee has 13 inmates serving life without parole for crimes they committed as juveniles, and roughly 100 other juvenile offenders who must serve a minimum of 51 years behind bars before being eligible for parole.

RESENTENCED OR RELEASED  
The state so far is not offering resentencing to the 13 juvenile life-without-parole inmates. As for the others, officials with Nashville's Juvenile Court have been pushing to reduce lengthy parole-eligible terms to 20 years for juvenile offenders. A state task force on juvenile justice reform could recommend changes.

LAW 
State lawmakers considered a bill this year that would allow juveniles to be eligible for parole after serving 20 years in prison. The bill was amended to make it 30 years, but the measure was pulled. The bill will be considered again next year.

State story

Texas has 12 inmates serving mandatory life-without-parole sentences for crimes committed as juveniles.

RESENTENCED OR RELEASED  
None of the 12. State lawmakers in 2009 passed legislation banning life without parole for offenders 16 and younger and then, four years later, prohibited the sentence for 17-year-olds as well, instead mandating a sentence of life with the opportunity for parole after 40 years.

LAW 
A bill that would have cut in half the amount of time served before juvenile offenders are eligible for parole died this year in the state Legislature. Advocates plan to revive it next session. The Texas Criminal Justice Coalition said more than 2,100 juvenile inmates would have qualified for parole sooner. The law would also have required the Board of Pardons and Paroles to consider the “growth and maturity” of a youthful offender.

State story

Utah has two inmates serving discretionary life-without-parole sentences for crimes committed as juveniles.

RESENTENCED OR RELEASED  
One was denied a request for resentencing based on the argument that his attorney didn’t properly explain what he was agreeing to in a plea deal. The other appealed, arguing his sentence was “cruel and unusual punishment” due to his age. The Utah Supreme Court in 2015 denied his appeal, upholding his sentence.

LAW 
Although Utah law never required life in prison without parole for any juvenile - rather, it was discretionary - the state Legislature in 2016 eliminated the sentence of life in prison without parole for any defendant who is younger than 18 at the time of the offense.

State story

Vermont has no inmates.

LAW 
In 2015, Vermont eliminated life without parole for teens 17 and younger.

State story

Virginia has 51 inmates serving life without parole for crimes committed before 18.

RESENTENCED OR RELEASED  
At least two have been resentenced despite an ongoing debate in the state over whether its juvenile lifers fall under the Supreme Court rulings. In the capital murder cases, attorneys for inmates argue they’re entitled to new sentences because state law gives judges just one option in sentencing.

LAW 
Life without parole is still on the books in Virginia. People convicted of capital murder for crimes committed as adults can be sentenced to death, but Virginia law says that for juveniles the punishment “shall be” imprisonment for life. The sentence is also an option for other serious crimes committed by juveniles.

State story

Washington has 14 inmates still serving life without parole for crimes committed while they were juveniles.

RESENTENCED OR RELEASED  
17 others have been resentenced; two received new life-without-parole terms.

LAW 
Before 2014, juvenile offenders were treated the same as adults and would automatically get life without parole for first-degree murder. In 2014 and 2015, state lawmakers revised a statute to include specific sentencing instructions for 16- and 17-year-old offenders convicted of aggravated first-degree murder to ensure that mitigating factors be considered. The Legislature also allowed all those convicted before turning 18 and sentenced to 20 or more years in prison to petition for release after 20 years.

State story

West Virginia has no inmates.

RESENTENCED OR RELEASED  
In 2014, two years after the Supreme Court banned mandatory life without parole for juvenile killers, lawmakers enacted a measure that said anyone under 18 shall be eligible for parole after serving 15 years for serious crimes. The West Virginia Parole Board applied the legislation retroactively and identified seven juvenile lifers in murder cases for whom the new terms were applied. Five were denied parole after hearings in 2014 and will next appear before the panel in September.

LAW 
Life without parole is prohibited for juvenile offenders.

State story

Wisconsin has three men serving discretionary life-without-parole sentences. Another 70 juvenile offenders are serving life with the possibility of parole but are unlikely to be released because parole is so rare in the state.

RESENTENCED OR RELEASED  
None. One of the three juvenile lifers asked for a parole hearing based on the Supreme Court’s ruling, but was denied.

LAW 
Wisconsin has no mandatory life sentence without parole for juveniles. Judges can impose that sentence at their discretion, however.

State story

Wyoming has no inmates currently serving life without parole. Previously 13 had the sentence.

RESENTENCED OR RELEASED  
The state scrapped mandatory life without parole for juveniles in 2013, and passed a law making inmates eligible for parole after serving at least 25 years. Since then, one of 13 inmates has been freed and another was granted parole on July 19 and may be released soon. All the others will be eligible for parole hearings at some point.

LAW 
The 2013 law banned life without parole for minors and makes them eligible for parole after 25 years, provided they haven’t committed serious crimes in prison.

State story

Washington, D.C. has 100 inmates.

LAW 
A city law has prohibited life-without-parole sentences for juveniles for decades.

District story

About LOCKED UP FOR LIFE

Decades ago in the tough-on-crime ‘80s and ‘90s, many states — stoked by fears of teen “superpredators” — enacted laws to punish juvenile criminals like adults. The U.S. became an international outlier, sentencing offenders under 18 to live out their lives in prison for homicide and, sometimes, rape, kidnapping, armed robbery.

There has since been a shift. Five years ago, the U.S. Supreme Court banned mandatory life without parole for juveniles in murder cases. Then last year, the court went further, saying the more than 2,000 already serving such sentences must get an opportunity chance to show their crimes did not reflect “irreparable corruption” and, if not, have some hope for freedom.

The January 2016 ruling set the stage for an unprecedented second look at hundreds and hundreds of cases, some many decades old now, in courtrooms across America. The Associated Press leveraged its reporting power in all 50 states to examine how judges and prosecutors, lawmakers and parole boards are now revisiting juvenile lifer cases. Many have been resentenced and released, with more hearings continuing in the days, weeks and months ahead. But in some states, officials have delayed review of cases or fought to keep the vast majority of their affected inmates locked up for life.

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