Incarceration sentence length

In the United States, incarceration sentence lengths are either determinate or indeterminate. In imposing an indeterminate sentence, the judge sets the maximum length of time the offender can be confined before being released. A parole board decides when an adult offender with an indeterminate sentence is released; a juvenile court judge or an authorized State agency decides the release date for a juvenile offender with an indeterminate sentence. In most States, sentences imposed in adult courts and juvenile courts are indeterminate. Before 1987, sentences imposed in Federal courts were also indeterminate.

An adult sentence of "10 to 20 years" is an example of an indeterminate sentence. What makes the sentence indeterminate is the fact that, at the time of sentencing, the offender cannot know how long he or she will serve before being released because the offender cannot know when the parole board will grant release. All that is known is a specified time range.

By contrast, a determinate sentence has no time range: it is a single maximum period of time, such as "20 years." The length of time that the offender with a determinate sentence will serve is whatever maximum term was imposed, less whatever number of days or months was deducted from the sentence for good behavior or special achievements.

Before 1992 the English sentencing system was largely indeterminate. Except for sentences under 10½ months, all sentences were indeterminate. That changed in 1992, when a more determinate sentencing system was adopted. Today, as in 1992, the only sentences that are indeterminate are those that are at least 4 years long.

In the United States the maximum juvenile sentence is typically "until age 18" or "until age 21." In England, before 1992 the maximum was 1 year. In 1992 the maximum was set at 1 year for juveniles sentenced in the juvenile court and 2 years for those sentenced as juveniles in the Crown Court.

Unlike the United States, England does not have the death penalty. Both countries have life sentences, but there is a difference. In the United States, "life without the possibility of parole" and "life with the possibility of parole" are sentencing options available in most States. By contrast, life with the possibility of parole is the only type of life sentence available in English courts.

Which courts -- those in the United States or those in England -- impose longer incarceration sentences?