Motion to Preclude LWOP Pursuant to the Equal Protection Clauses of the Fourteenth Amendment and Article I, §3 of the Louisiana Constitution (for defendants who were convicted of or are facing Second Degree Murder, but were indicted prior to August 1, 2017)
Motion to Preclude LWOP Because the Imposition of LWOP on a Child Offender is Categorically Prohibited by the Eighth Amendment and Article I, Section 20 of the Louisiana Constitution
Motion to Prohibit the Application of Louisiana Code of Criminal Procedure Article 878.1 As Unconstitutionally Vague and Consequentially Arbitrary (What constitutes the “worst offender”? What constitutes the “worst case”?)
Motion to Hold Louisiana Code of Criminal Procedure Article 878.1 Unconstitutional As it Fails to Sufficiently Narrow the Category of Child Offenders Eligible for the Ultimate Punishment of LWOP
