Brandon Pardi was found guilty last December of dangerous driving causing the death of toddler Bianca Leduc.
The defence argues that a sentence in the community, with community service or a fine, would be sufficient punishment.
Pardi has appealed the verdict and his lawyer says he'll appeal any jail sentence. Quebec court Judge Michel Mercier will render a sentence on June 5.
Pardi's case gained national notoriety when he fought to be tried as a juvenile. However, Canada's highest court refused to hear his case.
Pardi was driving without a valid licence when he lost control while speeding with a friend in a residential area, striking the other boy's car and careening into the yard, killing a three-year-old girl as she hung Halloween decorations on her babysitter's lawn.