Apprendi after Miller and Graham : How the Supreme Court's Recent Jurisprudence on Juveniles Prohibits the Use of Juvenile Adjudications as Mandatory "Sentencing Enhancements"

Part I will introduce Supreme Court jurisprudence on the evolution of the juvenile court system and the extension of some procedural protections to juvenile delinquency proceedings. Part II will explain Apprendi v. New Jersey and the Court’s recognition of a “conviction exception.” Part III will discuss how federal courts have treated juvenile adjudications in light of the Apprendi exception. Part IV will discuss recent Supreme Court cases dealing with juveniles as a class distinguishable from adults, specifically the most recent cases of Miller v. Alabama and Graham v. Florida. Finally, in Part V, this note will address how Miller v. Alabama and Graham v. Florida reflect a change in the Court’s perception of juveniles. It advances the argument that, regardless of whether a juvenile adjudication was obtained by a jury, the Court’s view of juveniles as a class fundamentally distinct from adults prohibits equating juvenile adjudications with adult convictions under Apprendi.