New Death Sentences for Defendants Under Age 21 Have Virtually Vanished — Yet Three of Them Are Scheduled for Execution This Month

The death penalty has been unconstitutional for juveniles since 2005, when the U.S. Supreme Court ruled that people under age 18 lack the impulse control, foresight, and individuality that make adults more culpable for their crimes. In that decision, the Court acknowledged that the “qualities that distinguish juveniles from adults do not disappear when an individual turns 18.” Indeed, in the two decades since, experts have reached a broad consensus that emerging adults age 18, 19, and 20 display the same cognitive immaturity as juveniles, as the Death Penalty Information Center highlighted in a 2025 report. Today’s prosecutors and capital jurors appear to agree. Since 2020, an average of just one emerging adult per year has been sentenced to death in the entire country. Yet scheduled executions this month of three individuals under the age of 21 at the time of their crimes show the long tail of this practice — and its starkly unequal impact.

A New Societal Consensus? Data Show Steep Decline and Racial Bias

The Supreme Court’s landmark decision in Roper v. Simmons (2005) relied on scientific evidence of incomplete brain development and the growing reluctance of state and international lawmakers to permit death sentences for juveniles. The Court applied its longstanding test for cruel and unusual punishment under the Eighth Amendment, which “must draw its meaning from the evolving standards of decency that mark the progress of a maturing society.”

The Death Penalty Information Center’s (DPI) report, Immature Minds in a “Maturing Society”: Roper v. Simmons at 20, analyzed data since Roper to gauge how the law’s most severe punishment is imposed on individuals ages 18 to 20. DPI found that new death sentences for this age group are now so rare as to be functionally nonexistent. Only five counties in the entire United States — one-fifth of one percent — sentenced a person under age 21 at offense to death between 2020 and 2025. These sentences averaged out to just one per year, representing only 5% of all new death sentences for that same time period.

This trend has emerged alongside expert consensus that the human brain continues to develop well into the mid-twenties. Young people are more likely to take risks and submit to peer pressure, and less equipped to regulate their emotions and behavior — undermining the penological justifications for the death penalty. In the past decade, both the American Bar Association and the American Psychological Association have cited this rationale to call for criminal defendants under age 21 to be excluded from death penalty eligibility.

DPI also discovered disturbing racial disparities in death sentencing practices between people under and over age 21. Studies have shown that youth of color, particularly young Black men, are viewed as more culpable and punished more harshly than white youth who commit similar crimes. Since Roper, 79% of people sentenced to death for crimes committed at age 18 – 20 were non-white, compared to 57% of older people. Some states had as much as a 15-year gap in average age at crime between white and non-white capital defendants.

Yet despite these scientific and legal developments, as is often the case, executions do not reflect current sentencing practices. The three prisoners scheduled for execution this month for crimes committed under age 21 likely would not have been sentenced to death if tried today.

LeJames Norman and Ker’Sean Ramey: The Archetype of Youth Sentencing Disparities in Texas

The racial bias of under-21 capital sentencing is especially apparent in Texas. The state accounts for half of all executions of this age group since Roper, more than any other state — and 80% of those executed were people of color. Every prisoner currently on Texas death row for a crime committed under age 21 is non-white. Texas executed 13 people for juvenile offenses in the years before Roper, nine of whom were Black or Latino, including Napoleon Beazley, who was the subject of an international clemency movement. Texas also had the greatest number of prisoners freed from death row as a result of Roper, with 29; 22 (76%) were non-white.

Read more about racial bias in Texas capital sentencing in recent reports from the Texas Defender Service.

Texas’ sentencing practices further illustrate how different the crimes of adolescents are from those of adults, reflecting the fact that youth are more susceptible to peer pressure and impulsive decision-making. DPI analyzed Texas executions since Roper to determine whether those under 21 were more likely to 1) have been tried alongside codefendants, or 2) commit robbery as part of their capital crime. DPI found that 64% of these young people had codefendants and 73% had committed robbery—twice the rate of adults in both categories.

The Texas executions this month are a quintessential example of these dynamics. Both Black, LeJames Norman was 19 and Ker’Sean Ramey was 20 when they broke into a rural home in 2005 looking to steal cocaine, resulting in a confrontation that ended in the deaths of three people living there. Mr. Norman was executed on September 16 and Mr. Ramey is scheduled for execution on September 23.

In his clemency campaign, Mr. Ramey has argued that his death sentence is unjust for several reasons, among them that his trial attorney, a full-time dentist who ran a solo law practice at night, had never tried a capital case and later had his legal license suspended for client neglect. The attorney presented no guilt-phase witnesses, failed to object to the prosecution’s strikes of all Black potential jurors, failed to investigate or present evidence of Mr. Ramey’s abusive and impoverished childhood, and bungled Mr. Ramey’s direct appeal. Given the absence of any meaningful mitigating evidence, the nearly all-white jury took just 14 minutes to sentence him to death. Experts have noted that young defendants like Mr. Ramey are often less equipped to assist their attorneys in their defense.

Mr. Ramey’s clemency campaign also argues that he has grown and changed — another point the Roper Court relied on to exclude juveniles from the death penalty. He has expressed strong remorse for his actions and contends that, after spending half his lifetime on death row, he is no longer the immature and impulsive adolescent he once was. Mr. Ramey would be the fifth Black man Texas executes in a row, and the fifth person Texas executes for a crime committed under age 21 in the past two years.

“An Outlier by Tennessee’s Own Standards”: Christa Pike’s Case Illustrates Impact of Childhood Trauma on Youth Offending

Christa Pike is scheduled to be executed September 30. She would be the first person put to death in Tennessee for a crime committed at age 18 in the modern era (since 1972), and the first woman executed in the state in over 200 years.

Ms. Pike was sentenced to death for the 1995 killing of a fellow member of a job corps program for troubled youth. Ms. Pike’s codefendant Tadaryl Shipp, just a few months younger than her, was sentenced to life because he had not yet turned 18. A week after the state issued Ms. Pike’s execution warrant last fall, Mr. Shipp became eligible for parole despite courts describing him as equally or more culpable.

DPI has found that youthful offenders often experienced severe deprivation in childhood, and Ms. Pike’s case serves as a poignant illustration. Her mother drank heavily while pregnant, causing brain damage visible on an MRI. As a toddler, Ms. Pike was sexually abused by her grandmother’s boyfriend, and later experienced multiple violent rapes as a teenager. Her clemency petition argues that her actions at 18 years old cannot be separated from the horrific abuse that was ignored by the adults and state systems meant to protect her. Her trial attorney “characterized her as less mature at 18 than his 10-year-old daughter.”

Ms. Pike is one of only eight prisoners to be sentenced to death in Tennessee in the modern era for a crime committed at 18; the seven others, all men, each were resentenced to life or less. No 18-year-old has been sentenced to death in Tennessee since Ms. Pike thirty years ago. She also spent years in functional solitary confinement as the only woman on death row until she won a lawsuit against the state in 2024.

In a 2019 federal circuit court ruling denying relief, Judge Jane Stranch wrote separately that executing young people like Ms. Pike was likely unconstitutional — but that federal law restricted her ability to overturn state court rulings. “[I]n sentencing Pike to death, we rule out the possibility that her crime was a product of the immature mind of youth rather than fixed depravity,” Judge Stranch wrote. “And we presume that she is incapable of reform even though the stories of other teenage killers, many of whom have been rehabilitated behind bars, reveal other possibilities. The judgment that she merits the most severe punishment is in tension with Supreme Court precedent focusing on the lesser blameworthiness and greater prospect for reform that is characteristic of youth.”