Catherine Elliott (2011) argues that both the abolition of doli incapax and the age of criminal responsibility in England of ten years and above, does not take into account the fact that young outside these parameters they still have reduced mental capacity and lack the freedom to choose how to behave (p. 289). The argument here is that childhood and development do not end at age ten and that the justice system must recognize this. Additionally, an eleven-year-old youth should not face the same burden of the justice system as a fully developed adult. The UK government justified “the abolition of the doli incapax defense on the basis that [it] would send a clear signal that, in general, children aged ten and over should be held accountable for their actions” ( Elliott, 2011, p. 292 ). Holding young people accountable means making them take responsibility for their behaviors (Minaker & Hogeveen, 2009, p. 102). The question then becomes: how can we empower young people while recognizing their reduced capacity and development? Turning to a biological explanation, Elliott (2011) states that factors, such as the frontal lobes of the brain, play an important role in the development of self-control and impulsivity (p. 294). A young person's brain is still developing and this affects their behavior. “Considerable evidence supports the conclusion that children and adolescents are less capable decision makers than adults in some ways