This brief is presented for Jose Martinez High v. Walter Zant and Heath A. Wilkins v. State of Missouri in the 1988 October term of the U.S. Supreme Court. Both cases involve a determination of the constitutionality of imposing the death penalty on juveniles. The brief reasons that because our criminal justice system is based on concepts of individual responsibility, the differences between minors and adults in their capacities to assume such responsibility, recognized in other legal contexts, should be reflected in the response to crimes committed by minors. Some minors who commit serious crimes must be subject to trial and sentencing in the criminal justice system in order to protect society and vindicate the criminal laws; however, the fact that a minor is appropriately tried in the criminal justice system does not mean that the imposition of capital punishment is appropriate. The death penalty is reserved for people whose crimes are so severe, whose character is so depraved, and whose moral culpability is so great as to warrant the ultimate sanction. Since in other legal contexts the courts conclusively presume that minors under the age of 18 are not mature and responsible to the same extent as adults, they should not be held to the degree of moral accountability necessary to justify the ultimate sanction of execution. Table of authorities.