LANDMARK CASES IN FORENSIC PSYCHIATRY:
Child Cases | Juvenile Sentencing
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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.