Law School Case Brief
Graham v. Florida - 560 U.S. 48, 130 S. Ct. 2011 (2010)
The U.S. Constitution prohibits the imposition of a life-without-parole sentence on a juvenile offender who did not commit homicide. A State need not guarantee the offender eventual release, but if it imposes a sentence of life it must provide him or her with some realistic opportunity to obtain release before the end of that term.
Petitioner Graham was 16 when he committed armed burglary and another crime. Under a plea agreement, the Florida trial court sentenced Graham to probation and withheld adjudication of guilt. Subsequently, the trial court found that Graham had violated the terms of his probation by committing additional crimes. The trial court adjudicated Graham guilty of the earlier charges, revoked his probation, and sentenced him to life in prison for the burglary. Because Florida has abolished its parole system, the life sentence left Graham no possibility of release except executive clemency. He challenged his sentence under the Eighth Amendment's Cruel and Unusual Punishments Clause, but the State First District Court of Appeal affirmed.
Did the Eighth Amendment's Cruel and Unusual Punishments Clause prohibit the imposition of a life-without-parole sentence on Graham?
The U.S. Supreme Court held that U.S. Const. amend. VIII prohibited the imposition of a life-without-parole sentence on Graham who committed a nonhomicide crime and, while Graham need not be guaranteed eventual release from the life sentence, he must have some realistic opportunity to obtain release before the end of the life term. The practice of sentencing a juvenile who did not commit a homicide offense to life without parole was exceedingly rare and a national community consensus developed against it, and none of the recognized goals of penal sanctions, i.e., retribution, deterrence, incapacitation, and rehabilitation, provided an adequate justification for the sentence. Further, it could not be conclusively determined at the time of sentencing that Graham would be a danger to society for the rest of his life, and a sentence of life without parole improperly denied the juvenile offender a chance to demonstrate growth, maturity, and rehabilitation.
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