The legal landscape has changed significantly since 14-year-old Qu’eed Batts showed up on the front porch of an Easton, Pa., home, shot Clarence Edwards in the head and then shot a fleeing Cory Hilario in the back.

It was 2006, and just a year earlier, the U.S. Supreme Court decided Roper v. Simmons, 543 U.S. 551 (2005). Roper held that subjecting juveniles to the death penalty violated the Eighth Amendment’s prohibition against cruel and unusual punishment.