Juvenile Law Center

Juvenile and Criminal Justice

Brown v. Bowersox

Norman Brown was fifteen years old and unarmed when he participated in a robbery in Missouri under the guidance and encouragement of an adult nearly twice his age. The armed adult co-defendant used young Brown as a decoy as he went into the store and killed the store clerk. Brown was convicted of first degree murder under the theory of accessorial liability, which extended criminal liability for the murder to anyone who participated in the robbery, and sentenced to mandatory life without parole.

Juvenile Law Center, along with National Association for Public Defense, and Missouri Association of Criminal Defense Lawyers filed an amicus brief in support of Norman Brown’s petition for writ of certiorari in the United States Supreme Court. Amici urged the Court to grant certiorari to clarity that juveniles who did not kill or intend to kill cannot be sentenced to life without parole. Amici argued that, as applied to juveniles, the rationale underlying accessorial liability is inconsistent with United States Supreme Court jurisprudence and adolescent development research highlighting youth’s reduced culpability and diminished ability to foresee or anticipate future consequences.

On January 9, 2017, the United States Supreme Court denied Mr. Brown’s petition.


Case Number
Amicus Curiae
November 17, 2016
State of Origin

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