LANDMARK CASES IN FORENSIC PSYCHIATRY:

Child Cases | Juvenile Sentencing

Graham v. Florida, 2011

Case Summary:

  • Graham, a teenager, pled guilty to burglary charges & was sentenced to jail and probation. He subsequently violated probation, participating in a home invasion, for which the judge sentenced him to what equated to life in prison without the possibility of parole.

  • Graham argued that a sentence of life without parole for a non-homicide offense committed as a juvenile violated his 8th Amendment Right to protection from Cruel & Unusual Punishment.

  • US Supreme Court ruled that sentences of life without parole for non-homicide offenses committed as a juvenile are unconstitutional.

Key Concepts:

  • Under the 8th Amendment, life sentences without the possibility of parole for non-homicide offenses committed as a juvenile are unconstitutional.

  • Extended the diminished culpability reasoning used in Roper v. Simmons.

Miller v. Alabama, 2012

Case Summary:

  • Miller, a juvenile, was convicted of murder and sentenced to life without the possibility of parole under Alabama’s mandatory sentencing scheme.

  • US Supreme Court ruled that mandatory life without parole sentencing schemes for offenses committed as a juvenile are unconstitutional under the 8th Amendment.

Key Concepts:

  • Mandatory life without parole sentencing schemes for offenses committed as a juvenile are unconstitutional under the 8th Amendment.

  • Life without parole sentences for homicide offenses committed as a juvenile are not prohibited, but cannot be mandated, as to allow for consideration of other factors, including age.