informed responses to youth in juvenile justice institutions are very different from one another.
Yet in the above example, the differences are not based on the behaviors of the youth (which do
not vary). Instead, the three different responses are based on the court’s decision of which model
to apply. Arguably the new trauma-informed model fits best with Miller’s views of the
adolescent brain and youth development.
VI. CONCLUSION
Juvenile courts should consider child trauma issues at sentencing consistent with the
guidelines set forth by the Miller Court. After reviewing the recent Supreme Court decisions on
juvenile sentencing, this Article described what is meant by child trauma, and identified its
developmental impact and prevalence in the juvenile justice system. Given that adult criminal
courts have considered one type of trauma, PTSD, in sentencing, juvenile courts should also be
able to consider child trauma in sentencing. This Article described how the juvenile court system
might conduct trauma-informed sentencing. Such use of a trauma-informed approach in juvenile
court is consistent with Miller and would benefit the youth, their families, the juvenile justice
system, and society.
