The Parole Mirage: Georgia’s Broken Promise to Juvenile Lifers

If Justice Is Blind, Must It Also Be Silent?

Author’s Note

Before becoming a juvenile court judge, I spent ten years working inside the Georgia parole system — first as a parole officer in the streets of inner-city Atlanta, later as chief parole officer, and finally as assistant director of field services overseeing statewide offender programming. That time taught me a great deal about the broken machinery of back-end justice. It also gave me a firsthand view of how adult systems treat youth — and fail them.

Later, as a juvenile court judge and now as a college professor teaching courses like Juvenile Justice Procedures, Criminal Law, and Contemporary Issues in Criminal Justice, I’ve made it a point to return again and again to one painful reality: kids are not adults — not in their minds, not in their biology, and not in how we should treat them under the law.

The U.S. Supreme Court in Graham v. Florida declared that children sentenced to life must receive “some meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation.” That wasn’t a casual suggestion — it was a constitutional mandate, one rooted in science. Miller v. Alabama and Montgomery v. Louisiana followed, reinforcing that youth must be treated differently because they are different.

Those landmark rulings were grounded in neuroscience showing that the human brain — especially the frontal lobe responsible for impulse control and decision-making — does not fully develop until around age 25. This explains why teenagers are more likely to act irrationally, take dangerous risks, and respond emotionally rather than logically. It also explains why they are more capable of change than adults. We do not excuse their behavior — but we must understand it before we sentence them to die behind bars.

That’s why I’ve spent my career fighting against laws that automatically treat youth as adults. Georgia’s 1994 law requiring mandatory prosecution of children as young as 13 in adult court was, in my view, a profound step backward. Decisions about transferring youth to adult court should remain with juvenile court judges who know how to weigh a child’s capacity for rehabilitation against the seriousness of the offense.

Image generated with ChatGPT/DALL·E (OpenAI) with the following direction by the author: “A poster depicting a prison cell with a juvenile behind the bars and overhead are the words ‘The Parole Mirage: Georgia’s Broken promise to Juvenile Lifers’” November 16, 2025.

Two federal lawsuits filed in Georgia are challenging the state’s Board of Pardons and Paroles, claiming that its parole process — particularly for individuals imprisoned as teenagers — violates landmark U.S. Supreme Court rulings. Based on my 22 years as a juvenile court judge, and carving out special time as a college professor in my juvenile justice procedures classes to explore how juvenile lifers differ than adult lifers within the context of parole considerations, I agree. These lawsuits expose a disturbing truth: Georgia’s system offers little more than a performative nod to the constitutional promise of a second chance for children.

These lawsuits focus on a glaring disconnect between what the Constitution demands and what Georgia delivers. The Supreme Court, through decisions like Miller v. Alabama, Montgomery v. Louisiana, and Graham v. Florida, held that youth must be treated differently in the justice system — not just at sentencing, but at every stage where the possibility of rehabilitation is evaluated. The Court made it clear: children sentenced to life must receive a “meaningful opportunity for release.” In Georgia, that opportunity exists only on paper. In other words, kids are constitutionally different.

Take Janice Buttrum. At 17, she committed a horrific crime with her 28-year-old husband — a man she married at age 15 after a childhood marked by abandonment, foster care, and sexual abuse. Convicted and sentenced to death in 1981, her sentence was later commuted to life with parole in light of evolving constitutional standards. That should have meant a second chance. But 44 years later — after completing more than 60 rehabilitative courses, earning a spot in Pulaski State Prison’s Honor Dorm, and receiving no disciplinary reports in over two decades — Buttrum remains behind bars. She has been denied parole five times, with no explanation beyond vague references to the “nature of the offense” and “not enough time served.”

This is not justice. It is bureaucratic inertia masquerading as discretion.

The U.S. Supreme Court in Graham made clear: “A State is not required to guarantee eventual freedom,” but it must provide “some meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation.” Georgia’s parole process, however, offers only the illusion of meaning. It’s a locked door with a sign that reads “Hope,” but no keyhole in sight.

There are more than 500 people in Georgia prisons serving life with parole for crimes they committed as children. Some have waited 30, 40, even 50 years for release. Six have died while waiting — just in the past two years. Parole consideration is not supposed to be a second sentencing trial. It should be a sincere examination of who the person is today, not a replay of the past. And yet, for Buttrum and others like her, the Parole Board continues to deny release based solely on the original crime, ignoring decades of growth and rehabilitation.

Image generated with ChatGPT/DALL·E (OpenAI) with the following direction by the author: “A poster depicting a prison cell with a juvenile lifer, now an adult, sitting on his bed reading a notice from the parole board denying his parole based only on the nature of the offense with a calendar on the wall marking 40 years in prison and written on the wall behind home the excerpt from Graham vs. Florida regarding ‘meaningful opportunity’ ” November 16, 2025.

The Board’s process is a black box. There is no hearing. No rationale. No explanation. No judicial-style findings. Just silence — the same kind of silence that greeted these individuals in their trauma-filled childhoods. The Board’s spokesperson assures the public that all cases receive “meaningful consideration,” but that phrase, devoid of transparency or accountability, is as hollow as a drum. How does one measure whether something has been “meaningfully considered” when those doing the considering offer no reasons, no standards, and no findings to explain their decisions?

Let’s be clear: the U.S. Supreme Court in Greenholtz v. Inmates of the Nebraska Penal and Correctional Complex, 442 U.S. 1 (1979), and Connecticut Board of Pardons v. Dumschat, 452 U.S. 458 (1981), held that parole is not a constitutional right. In the absence of a state-created entitlement or specific statutory mandate, parole boards are not required under the Due Process Clause to provide explanations for denial.

The Georgia Supreme Court adopted this reasoning in Georgia State Board of Pardons and Paroles v. Turner, 248 Ga. 767, 285 S.E.2d 731 (1982), where an inmate, Turner, argued that he was entitled to a written explanation for his parole denial. Citing Greenholtz and Dumschat, the court concluded that since Georgia law grants the Parole Board sole discretion over parole decisions, no constitutional violation occurred by failing to provide detailed reasons. The Board had informed Turner that his denial was due to the “circumstances and nature of his offense,” which the court deemed sufficient under federal constitutional standards, given that no further justification was legally required.

It’s not uncommon for long-established state agencies like parole boards — operating for decades under a legally accepted framework — to overlook the seismic implications of a single phrase buried in a U.S. Supreme Court opinion. In Graham v. Florida, amongst pages of legal reasoning, the Court included this deceptively simple but transformative mandate: states must provide “some meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation.” That one line altered the constitutional landscape for how juvenile lifers must be treated.

Even if Georgia’s parole officials noticed the phrase, the question remains: did they fully grasp its significance? After all, Graham involved a child sentenced to life without parole — and that context matters. This wasn’t a general pronouncement on parole procedures; it was a constitutional recalibration specific to youth. The phrase “meaningful opportunity for release” has a different weight when applied to children — because they are categorically less culpable and uniquely capable of change. The failure to internalize and operationalize that principle is not just bureaucratic oversight. It’s constitutional neglect.

In sum, while Georgia law has long permitted parole boards to deny release without explanation, the Supreme Court carved out a constitutional exception for juveniles. In Miller, Montgomery, and Graham, the Court held that youth must be treated differently — and that life sentences must come with a genuine opportunity for release. That promise of meaning cannot be fulfilled with silence. A rote denial based solely on the offense — without acknowledging who the person has become — defies both the spirit and the substance of that mandate.

This practice not only violates the moral obligations imposed by the Court — it raises serious due process concerns under the Fourteenth Amendment. Parole may not be a constitutional right, but once a state creates the system, it must be administered fairly. In any courtroom, a judge must offer findings to explain a ruling. Yet the Parole Board, which effectively controls the back end of a juvenile’s sentence, faces no such burden. When rehabilitation is shown, there must be an explanation as to why it was deemed insufficient — especially when the individual was a child at the time of the crime.

These are not abstract legal principles. They are matters of justice, equity, and public conscience. Is the state truly honoring the Supreme Court’s requirement to give youth “a second look,” or is it disguising perpetual punishment in the robes of procedure?

As a juvenile court judge for more than two decades, I’ve seen firsthand how young people can change when given the right structure and support. I’ve long argued that no one should have the rest of their life defined by what they did at 14. But Georgia’s parole practices cling to the myth of irredeemability. It is sentencing by proxy — justice outsourced to a faceless board that offers no evidence of individualized review, no recognition of trauma, and no acknowledgment of change.

Parole should not be a relic of vengeance. It should be a vehicle for redemption. Yet for Georgia’s juvenile lifers, it has become a cruel endurance test — a waiting room with no exits and no explanations.

The Constitution demands more. So should we.

Steven Teske is a retired juvenile court judge and former chief parole officer and assistant director of field services for the Georgia State Board of Pardons and Paroles. He has testified before Congress on four occasions and numerous state legislatures on law and policy reforms. He is a past president of the Council of Juvenile Court Judges and served on the Georgia Commission on Criminal Justice Reform, Georgia Juvenile Justice State Advisory Group, Georgia Child Welfare Reform Council, the Federal Advisory Committee on Juvenile Justice, and past Chair of the Coalition for Juvenile Justice.