Graham v. Florida

Background

Terrance Graham was a teenager in Florida who committed two sets of serious crimes. At 16 he participated in an attempted restaurant robbery and pleaded guilty and was placed on probation. Less than a year later, at 17, he was accused of a home-invasion robbery and the court found he had violated probation. At a later hearing a judge revoked his probation, convicted him on earlier counts, and sentenced him to life in prison with no possibility of parole under Florida law.

Reasoning

The Court considered whether the Constitution allows a state to impose life without parole on someone who was under 18 when they committed a nonhomicide crime. The majority looked at laws and actual practice around the country (finding about 123 such prisoners, 77 in Florida), research on adolescent development, and the purposes of punishment. It concluded juveniles are less culpable and more capable of change, and that retribution, deterrence, incapacitation, and rehabilitation do not justify denying any meaningful possibility of release. The Court therefore held that the Eighth Amendment forbids life without parole for juveniles who did not commit homicide, but states must provide a realistic opportunity for release based on demonstrated maturity.

Real world impact

The decision affects juvenile prisoners, prosecutors, and state sentencing systems. States may not impose permanent no-release sentences on under-18 non-killers and must create a mechanism for parole or review. The ruling did not order immediate release for all affected prisoners; it reversed the Florida appellate decision and sent the case back for proceedings consistent with this opinion.

Dissents or concurrances

Some Justices joined the judgment while others dissented, arguing the Court overruled many legislatures and usurped policy decisions reserved for elected officials.