Supreme Court of the United States
Terrance Jamar Graham v. Florida
May 17, 2010176 L. Ed. 2d 825
Summary
The Supreme Court held that the Eighth Amendment's Cruel and Unusual Punishments Clause, made applicable to the States through the Fourteenth Amendment's Due Process Clause, forbids sentencing a juvenile offender to life imprisonment without parole for a nonhomicide crime. Applying the categorical framework of Roper, Atkins, and Kennedy rather than case-specific gross-disproportionality review, the Court found a national consensus against the practice (only 123 juvenile nonhomicide offenders serve such sentences nationwide, 77 of them in Florida) and independently concluded that juveniles' twice-diminished culpability, the severity of life without parole, and the failure of every recognized penological justification render the punishment cruel and unusual. A State need not guarantee eventual freedom but must provide some meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation; the judgment of Florida's First District Court of Appeal was reversed and the case remanded. Justice Alito, dissenting, would have confined the holding to life-without-parole sentences and declined to reach Graham's abandoned as-applied proportionality claim.
Holding
- Whether the Eighth Amendment permits a juvenile offender to be sentenced to life without parole for a nonhomicide crime.. No. The Eighth Amendment forbids the sentence of life without parole for a juvenile offender who did not commit homicide; those below age 18 at the time of a nonhomicide offense may not receive that sentence for it.
- Which proportionality framework applies to a categorical challenge to a term-of-years sentence.. The categorical approach used in the death-penalty cases (objective indicia of national consensus followed by the Court's exercise of independent judgment), not the gross-disproportionality analysis suited to challenges to a particular defendant's term-of-years sentence.
- Whether objective indicia demonstrate a national consensus against life without parole for juvenile nonhomicide offenders.. Yes. Actual sentencing practices, not statutory eligibility alone, are the measure of consensus; the sentence is exceedingly rare even where authorized, so a national consensus has developed against it.
- Whether, in the Court's independent judgment, life without parole for juvenile nonhomicide offenders is justified by legitimate penological goals.. No. Retribution, deterrence, incapacitation, and rehabilitation each fail to justify the sentence, which is by its nature disproportionate to the offense.
- What the Constitution requires of States in place of life without parole for juvenile nonhomicide offenders.. A State need not guarantee eventual freedom, but it must give defendants like Graham some meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation.
- Whether a categorical rule is necessary rather than reliance on state procedural safeguards or case-by-case consideration of youth.. Yes. Neither Florida's charging laws nor a case-specific gross disproportionality inquiry taking account of age adequately addresses the constitutional concerns.
Docket No. 08-7412
Cited authorities
- Ariz. Rev. Stat. Ann. § 13-1423
- Fla. Stat. § 921.002(1)(e)
- Fla. Stat. § 985.557
- Ind. Code § 35-50-2-8.5(a)
- Iowa Code § 709.2
- Iowa Code § 902.1
- Mo. Rev. Stat. § 558.018
- Neb. Rev. Stat. § 28-416(8)(a)