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There have been many studies done over the past twenty five years attempting to find the differences in the adult mind compared to the child or adolescent mind. In a study done by Elizabeth Powell, studying the functional differences in the adolescent brain may provide evidence that the nervous system is responsible for behavior in adolescents between the ages of thirteen and nineteen. “They tend to act impulsively and irrationally. Testing limits, experimenting, and acting without considering future consequences.” These are all part of adolescent behavior according to Dr. Laurence Steinberg of Temple University, he states that teenage self regulation and impulsive behavior does not appear to regulate until later in adolescents. Dr. Laurence also wrote that the once thought teenage rebellious “phase” that had always been dismissed as simple hormone imbalance because of growth. This could simply be inaccurate, that the most likely cause of these rebellious outbursts and indiscretions is most likely caused by the functional differences in the teenage brain. The differences between the adult brain and the adolescent brain are most noticeable as the adolescent gains increased decision making the freedoms to make those choices. Studies in the variations in the brains of adolescents and adults provide evidence that the actions of the nervous system are responsible for observed behaviors. There have been two major studies published identifying the differences in the adult brain and the adolescent brain. The first of those studies was conducted then published by; Dr. Arthur Toga of the Laboratory of Neurological Imaging located the University of California. The study demonstrated that children between the ages of twelve and sixteen had a smaller myelination in the frontal lobes of the brain. These studies have identified that this area of the brain is responsible for dictating rational behavior and reasoned weighing of consequences. The myelin process takes neural cells and isolates lipid layers around the nerve process. The myelinated processes can more effectively conduct electrical signals from one neuron to another. Because adults have more myelin in there frontal lobes it implies that there are more neurons connecting therefor making decisions and understanding the consequences of those decisions more likely. Because there is a decreased number of myelination in adolescents it may mean that the neurons in children and adolescents frontal lobes are not as connected as adults, resulting in a decreased interconnection and not as capable of communicating the passing neurons like the adults passing neurons. The second study was performed by Dr. Giedd of the National Institute of Mental Health. Dr. Giedd studied the adolescent brain using magnetic resonance imaging. Dr. Giedd has identified a growth period of the neuron bodies or gray matter in the prefrontal cortex; this is a specific section of the frontal lobe. Even though adolescents contain more grey matter than adults neurons are connected through the teenage years so the development of the frontal lobes occurs gradually throughout adolescents, Dr. Giedd concludes that the adolescent brain has not made enough neurological connection and that the brain requires futher development through adulthood to full mature into being able to make effective decisions and understand the consequences of those decisions. Published on the American Bar Association website is an article from the Juvenile Justice Center, Cruel and Unusual Punishment: The Juvenile Death Penalty, Adolescence, Brain Development and Legal Culpability. “[They] frequently know the difference between right and wrong and are competent to stand trial. Because of their impairment, however, by definition they have diminished capacities to understand and process mistakes and learn from experience, to engage in logical reasoning, to control impulses, and to understand the reactions of others…. Their deficiencies do not warrant an exemption from criminal sanctions, but they do diminish their personal culpability.” Atkins v. Virginia, 536 U.S. 304, 318, 122 S. CT. 2242, 2250 (2002) In 2002 the U.S. Supreme Court banned the death penalty for mentally retarded persons, due to their diminished mental capabilities. Taken directly from this article the following excerpt: “In 2002, the U.S. Supreme Court banned the execution of mentally retarded persons. This decision, Atkins v. Virginia, cited the underdeveloped mental capacities of those with mental retardation as a major factor behind the Justices’ decision. Adolescence is a transitional period during which a child is becoming, but is not yet, an adult. An adolescent is at a crossroads of changes where emotions, hormones, judgement, identity and the physical body are so in flux that parents and even experts struggle to fully understand. As a society, we recognize the limitations of adolescents and, therefore, restrict their privileges to vote, serve on a jury, consume alcohol, marry, enter into contracts, and even watch movies with mature content. Each year, the United States spends billions of dollars to promote drug use prevention and sex education to protect youth at this vulnerable stage of life. When it comes to the death penalty, however, we treat them as fully functioning adults.”