Abstract
InGraham v. Florida, the US Supreme Court addressed the application of the Eighth Amendment prohibition against cruel and unusual punishment in cases involving juvenile offenders. The Supreme Court held that the Eighth Amendment prohibits the government in juvenile offender cases from imposing a lifetime sentence without the possibility of parole for nonhomicide crimes. TheGrahamCourt's Eighth Amendment analysis is noteworthy because for the first time the Court applied a categorical rule to a nondeath penalty case. TheGrahamdecision is also noteworthy because the Court inMiller v. Alabamaused theGrahamrationale to create a categorical rule prohibiting the imposition of mandatory lifetime sentences without the possibility of parole in homicide cases involving juvenile offenders.
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