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In October 2019, the Schubert Center for Child Studies provided a statement of interest for a brief of amicus curiae by the Office of the Ohio Public Defender, Juvenile Law Center and others. The argument for the petitioner’s proposition of law includes

1. A juvenile offender’s sentence is unconstitutional when the trial court does not consider youth when it sentences him to a life tail
2. The future possibility of discretionary parole is not an adequate substitute for individualized sentencing
3. The growing trend in favor of individualized sentencing for children underscores the unconstitutionality of the sentence imposed in this case (Kyle Patrick V. State)
4. A juvenile offender’s sentence is unconstitutional when it denies him the opportunity to appear before the parole board while it is still meaningful. The court’s understanding of what is considered a “meaningful opportunity� for a teenager and the implications of the court’s decision are of distinct concern to the Schubert Center.