Graham v. Florida

Annotation

PRIMARY HOLDING

Sentencing a juvenile defendant who did not commit homicide to life imprisonment without the possibility of parole violates the Eighth Amendment because it is disproportionate to the crime. These juveniles should have an opportunity to show that they can mature and reform their behavior.

FACTS

After committing armed burglary and attempted armed robbery, among other offenses, a teenager named Graham was tried as an adult. He pleaded guilty and was sentenced to concurrent three-year terms of probation. Within six months of his release from jail, where he spent the first 12 months, he violated the terms of his probation by committing more crimes. After Graham was arrested again, the same court sentenced him to life imprisonment without parole for the original burglary. He brought a motion under the Eighth Amendment on the grounds that the sentence violated its proportionality requirement, but the trial court denied the motion.OPINIONS

Majority

  • Anthony M. Kennedy (Author)
  • John Paul Stevens
  • Ruth Bader Ginsburg
  • Stephen G. Breyer
  • Sonia Sotomayor

Under the Eighth Amendment, the punishment for a crime must be proportionate to the offense. This issue tends to arise when defendants challenge the length of their sentences, based on their underlying crimes, or when they challenge the application of the death penalty. Courts reviewing such petitions must consider all of the circumstances of the case. Generally, a sentence will violate the Eighth Amendment if it is grossly disproportionate to similar offenders in the same jurisdiction and people convicted of the same crime in other jurisdictions. A life without parole sentence is not permissible if the defendant is under 18 or intellectually challenged. This is based on the application of the proportionality doctrine to death penalty cases, in which the characteristics of the offender are considered in addition to the nature of the offense. While there is no nationwide consensus against sentencing a juvenile to life in prison without parole, these sentences are extremely rare in proportion to the number of situations when they may be applied under state law. The proportionality doctrine requires considering whether the punishment serves legitimate penological goals in view of the particular offender and crime. These are deterrence, incapacitation, retribution, and rehabilitation. A sentence of life without parole will not produce the desired deterrent effect for juveniles because they lack maturity and cannot be expected to curb their behavior as a response. It also fails to serve the goal of incapacitation because it is difficult to imagine that any juvenile would be incorrigible. The sentence clearly does not serve the goal of rehabilitation, since the juvenile never would return to society. Individuals of this age must have a meaningful opportunity to rejoin society if they can show that they have turned a new leaf. The retributive purpose alone cannot justify a sentence that is cruel and unusual because of its disproportionate character and lack of connection to other appropriate penological goals.

Concurrence

  • John Paul Stevens (Author)
  • Ruth Bader Ginsburg
  • Sonia Sotomayor

Concurrence

  • John G. Roberts, Jr. (Author)

Dissent

  • Clarence Thomas (Author)
  • Antonin Scalia
  • Samuel A. Alito, Jr.

Dissent

  • Samuel A. Alito, Jr. (Author)

CASE COMMENTARY

This decision shows that minors and other special groups, such as the mentally ill, receive greater constitutional protections in the criminal sentencing process. The Supreme Court emphasized the importance of rehabilitation for juvenile offenders and continued to prohibit life imprisonment for offenses other than homicide involving them.

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