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.
The defendant was 16 years old when he committed armed burglary with assault and attempted robbery. Though a juvenile, he was charged as an adult and he pleaded guilty to the charges. Later on he was adjudicated guilty after violating conditions of probation, and received the maximum sentence of life imprisonment without parole. This left him with no possibility of release except upon executive clemency. On appeal, the defendant contended that, as a juvenile who did not commit or intend to commit homicide, the sentence of life imprisonment without parole constituted cruel and unusual punishment.
Does the Constitution permit a juvenile offender to be sentenced to life in prison without parole for a nonhomicide crime?
The U.S. Supreme Court held that U.S. Const. amend. VIII prohibited the imposition of a life-without-parole sentence on the juvenile offender who committed a nonhomicide crime and, while the defendant 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 the juvenile defendant 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.