What is a juvenile life sentence?

A juvenile life sentence sends someone who was under 18 when the crime happened to prison for life. In its harshest form, juvenile life without parole, there is no chance of release, ever. E. Jay Flowers received that sentence at 16. This page takes about three minutes to read.

Why children are treated differently

The U.S. Supreme Court has said that young people are different from adults: they are less mature, more impulsive, more influenced by others, and more capable of change. Because of that, the Court has limited how harshly children can be punished, one step at a time.

What the Supreme Court has decided

2005, Roper v. Simmons: no death penalty for crimes committed before age 18.
2010, Graham v. Florida: no life without parole for young people convicted of crimes other than homicide.
2012, Miller v. Alabama: mandatory life without parole for anyone under 18 is unconstitutional. Judges must be able to consider a young person’s age and circumstances first.
2016, Montgomery v. Louisiana: the Miller decision applies to people already serving these sentences. States can do this by offering parole hearings.
2021, Jones v. Mississippi: a judge may still give a child life without parole without first finding that the child can never change, as long as the sentence isn’t mandatory. States are free to ban it entirely.

Sources: The Sentencing Project, National Conference of State Legislatures.

Where things stand today

28 states and Washington, D.C. have eliminated juvenile life without parole (as of February 2026).
At the start of 2020, 1,465 people were serving life without parole for crimes committed as children, down 44% from the 2012 peak.
62% of people serving these sentences, where race is known, are African American.

Sources: NCSL, The Sentencing Project.

What it means in Arizona

Arizona abolished parole for homicide in 1994. For a young person convicted of first-degree murder, a judge chooses between two sentences: natural life, with no possibility of release, or life with the possibility of release after 25 years. With parole gone, that second option rarely led to release in practice.

After the Miller decision, Arizona passed a 2014 law making people sentenced to life with the possibility of release, for crimes committed before 18, eligible for parole once they serve their minimum sentence. Arizona still allows judges to sentence children to natural life.

Sources: SCOTUSblog, A.R.S. § 13-716 (2014).

In E. Jay’s words

Lindsey had no clue what those simple words meant
to the 16-year-old who received the
life without parole sentence.
E. Jay Flowers, Dog Program

Very few positive things have ever been granted to me
during this three-decade stay
inside the Arizona State Prison system.
E. Jay Flowers, Dog Program

“No matter how damaged I am,
this is me, and I’m still trying
to do something positive,
still trying to find PURPOSE.”
E. Jay Flowers

Learn more

WHAT YOU CAN DO

This page is for general information and is not legal advice. Facts as of October 2026.