Report:

Juvenile Life Without Parole
in North Carolina

This report examined the cases of 94 people in North Carolina who were sentenced to life without parole for offenses committed between the ages of 13 to 17. Under current North Carolina law, judges are required to hold hearings and make findings regarding juvenile life without parole sentencing for all new cases as well as old ones. However, courts are processing these complex cases inconsistently, and the state may spend millions of dollars litigating the remaining 51 sentences over the coming years.

Among the study’s key findings:

Of the 94 people sentenced to life without parole as juveniles in North Carolina:

  • 51 are currently serving those sentences
  • 42 have been re-sentenced to non-LWOP sentences
  • 1 is awaiting a new trial.

In North Carolina, more than 60% of the JLWOP sentences studied were concentrated in just 11 counties.

This is due in part to the “inertia effect”: once a county began to impose a juvenile life without parole sentence, it was more likely to continue doing so.


Juvenile life without parole sentences have become exceedingly rare. Since 2011, there have only been five such sentences in the entire state, averaging less than one per year.

The report posits that the United States treats juveniles who come into conflict with the law in ways that disregard their age, human rights, and differences from adults; that imposition of these sentences is fundamentally unfair, as it varies significantly based on geography, quality of legal representation, child’s economic status, and race; and because children’s brains are still forming, they lack the ability to assess risks and use good judgment yet are also more capable of rehabilitation. The report recommends that juveniles should be held accountable for their offenses in age-appropriate ways that focus on reintegrating them into society, are applied fairly and consistently, and are more cost-effective for the state.

Source: Finholt, Ben and Garrett, Brandon L. and Modjadidi, Karima and Renberg, Kristen, “Juvenile Life Without Parole in North Carolina” (February 11, 2019). Duke Law School Public Law & Legal Theory Series No. 2019-16