Every one knows that to be forcibly taken away from home and family and friends and business and property, and sent across the ocean to a distant land, is punishment, and that oftentimes most severe and cruel.'

Approximately 250,000 juvenile offenders are prosecuted in adult criminal courts each year in the United States. 2 Once in adult court, minors are subject to the same procedures and punishments as adults. 3 Some juvenile offenders were sentenced to death until the 2005 Supreme Court decision in Roper v. Simmons categorically banned capital punishment for juveniles. 4 Since Roper, the Supreme Court has limited life without parole sentences for juveniles, banning the sentence for juveniles who have not been convicted of homicide in Graham v. Florida5 This past term, in Miller v. Alabama, the Court held that even juveniles convicted of homicide cannot be sentenced to life without parole under mandatory sentencing schemes; judges must have discretion to consider mitigating evidence before imposing such an extreme sentence. 6 This string of decisions recognizes fundamental differences between youth and adults and distinguishes some punishments as permissible for adults, but cruel and unusual for juveniles in adult court.