Tags: Criminal law, Sentencing, Eighth Amendment
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In the case of GRAHAM v. FLORIDA, the Supreme Court ruled that sentencing a juvenile offender to life in prison without parole for a nonhomicide crime is unconstitutional under the Eighth Amendment's Cruel and Unusual Punishments Clause. The Court considers objective indicators of society's standards and determines whether there is a national consensus against the sentencing practice at issue. The study shows that life without parole sentences for juvenile nonhomicide offenders are rare and exceptional, and recent developments in psychology and brain science support the observation that juveniles have reduced culpability and should not receive the harshest punishments. The Eighth Amendment forbids the sentence of life without parole for juvenile nonhomicide offenders because of their limited culpability and the severity of the sentence. The State must provide a meaningful opportunity for release based on demonstrated maturity and rehabilitation. The trial court erred in sentencing Terrance Jamar Graham to life imprisonment without parole.
A categorical rule should be established to ban life without parole for juvenile nonhomicide offenders due to constitutional concerns. Juveniles are less morally culpable than adults who commit the same crimes, and this should be considered when assessing their sentences. A case-by-case approach to proportionality review is necessary to distinguish between the few incorrigible juvenile offenders and the many who have the capacity for change. The Constitution prohibits life without parole for juvenile offenders, and a state that imposes it must provide a realistic opportunity for release. The "narrow proportionality principle" should be applied on a case-by-case basis, and if the sentence is grossly disproportionate to the offense, it should be invalidated as a violation of the Eighth Amendment.
The Court's decision to ban life-without-parole sentences for juvenile non-homicide offenders in every case goes beyond the Solem decision's case-by-case standard and is not justified by the Eighth Amendment or Court precedents. The decision is based on the Court's independent moral judgment, not a consensus, and raises concerns about the Court's expanding constitutional veto over democratic choices regarding appropriate punishment. The dissenting opinion clarifies that the decision only applies to life without parole sentences for juvenile nonhomicide offenders and not to sentences with a possibility of parole. The Court did not address whether the petitioner's sentence violates the narrow, as-applied proportionality principle.
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