Graham v. Florida

Background

A 16-year-old boy was charged as an adult after an attempted armed burglary and later a home-invasion robbery while on probation. The Florida trial judge revoked probation and imposed life in prison without the possibility of parole. Florida has abolished parole, so that sentence effectively denied any prospect of release except clemency.

Reasoning

The Court addressed whether the Constitution’s ban on cruel and unusual punishment forbids life without parole for juveniles who did not commit homicide. The majority examined statutes and actual sentencing practice and found that such sentences are rare and widespread legislative support for them is limited in practice. The Court relied on earlier rulings that juveniles are generally less blameworthy and more capable of change. Because life without parole is a uniquely severe, irrevocable punishment, the Court concluded it cannot be constitutionally imposed on offenders under 18 for nonhomicide crimes. The majority found that retribution, deterrence, incapacitation, and rehabilitation do not justify a categorical denial of any meaningful hope of release for juvenile nonhomicide offenders.

Real world impact

The decision bars outright imposition of life without parole for juvenile nonhomicide offenders and requires states to provide those offenders a realistic opportunity for release based on demonstrated maturity and rehabilitation. States may design the procedures and timing for that opportunity, and courts will apply the ruling to cases on remand. The rule does not categorically affect juvenile homicide sentences.

Dissents or concurrances

There are important separate views: one Justice concurred in the judgment but favored a case-by-case proportionality approach; others warned against imposing a broad categorical rule and defended legislative judgment and originalist limits.