## Facts

- Terrance Jamar Graham committed an attempted armed robbery at age 16 and was charged as an adult with armed burglary with assault or battery and attempted armed robbery.
- Graham pleaded guilty under an agreement; the trial court withheld adjudication, imposed probation, and required 12 months in county jail.
- After release, Graham was arrested again and accused of participating in a home invasion robbery and other offenses.
- At a probation-violation hearing, the trial court found Graham violated probation, adjudicated him guilty on the original charges, revoked probation, and sentenced him to life imprisonment for armed burglary plus 15 years for attempted armed robbery.
- Florida had abolished parole, making the life sentence effectively without parole, with release possible only through executive clemency.

## Issues

1. Whether the Eighth Amendment permits sentencing a juvenile to life imprisonment without parole for a nonhomicide offense.
2. Whether the Eighth Amendment requires a state to provide juvenile nonhomicide offenders a realistic opportunity to obtain release based on maturity and rehabilitation.

## Decision

- The Supreme Court reversed and remanded.
- The Court held that the Eighth Amendment prohibits life without parole for juvenile offenders who did not commit homicide.
- The Court required that states provide such offenders a meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation, without requiring any guarantee of release.
- The Court adopted a categorical rule rather than relying on case-by-case proportionality review for this sentencing practice.

## Legal Principles

- The Eighth Amendment’s proportionality principle supports categorical limits on certain punishments for defined classes of offenders and offenses, assessed using objective evidence of contemporary standards and the Court’s independent judgment.
- Juveniles are constitutionally different from adults for sentencing because of reduced culpability and greater capacity for change, weakening the penological case for the harshest punishments.
- A sentence that denies a juvenile nonhomicide offender any realistic release mechanism is categorically disproportionate under the Cruel and Unusual Punishments Clause.
- States may impose lengthy prison terms on juvenile nonhomicide offenders, but must provide a meaningful opportunity for release based on maturity and rehabilitation.

## Conclusion

The Court held that sentencing a person to life without parole for a nonhomicide crime committed before age 18 violates the Eighth Amendment, and it required states to provide juvenile nonhomicide offenders a meaningful opportunity to seek release based on demonstrated maturity and rehabilitation.


Graham v. Florida, 560 U.S. 48 (2010)