The latest round of Supreme Court decisions produced an interesting ruling which protects juveniles from life sentences for committing non-homicidal crimes. As a 16 year old, Terrance Graham was granted life in prison after he violated the terms of his parole from a previous armed robbery conviction by evading arrest in possible connection with yet another crime; thus resulting in a life sentence without parole except in the case of an executive clemency being granted. Graham then appealed his life sentence under the Cruel and Unusual Punishment Clause of the Eight Amendment, claiming the punishment did not fit the crime, but his sentence was later upheld by the district appellate court.
The case was then sent to the High Court for a final verdict, and in using precedent and proper application of the Eight Amendment, the court determined that, as a minor, Graham’s life sentence represented a disproportionate punishment in relation to the crimes he had committed. In his majority opinion, Supreme Court Justice Anthony Kennedy states “The concept of proportionality is central to the Eighth Amendment” and “Because there was no intent to commit homicide, it was determined that by national standards the punishment was cruel and unusual in relation to the act itself”. In addition, despite the defendants’ minor status, he would be denied any chance at rehabilitation under the Florida court’s decision. On the matter Justice Kennedy states, “The state has denied him any chance to later demonstrate that he is fit to rejoin society based solely on a non-homicide crime that he committed while he was a child in the eyes of the law.”
The High Court was also concerned with the potential over application, in varying forms, of the court’s precedent by the individual states in allowing a death or life sentence in this kind of case. Kennedy writes, “This case implicates a particular type of sentence as it applies to an entire class of offenders who have committed range of crimes.” In addition, Kennedy made it clear that the Eight Amendment trumped the need for states to enforce life sentences on minors who commit non-homicides. He states, “inadequacy of penological theory to justify life without parole sentences for juvenile non homicide offenders, the limited culpability of such offenders, and the severity of these sentences all lead the Court to conclude that the sentencing practice at issue is cruel and unusual.”
Ultimately, the lack of intent to commit murder seems to be the main factor in the 6-3 decision that has allowed Graham to potentially rejoin society. Despite his minor status, the Supreme Court would likely have held the district court’s decision had the act involved a homicide or the intent to kill. Therefore precedent has been set that should serve notice to juveniles who believe the system is designed to protect them from life sentences in all cases. The High Court also made it clear that the priority should be rehabilitation in cases such as this where the defendant has the potential to contribute to society.
This important ruling will give added clarity to the matter of what crimes are deemed atrocious enough to deem a minor responsible at an adult level. The fragile balance between overreaching punishment and commonsensical application of the criminal code has been appropriately defined in the majority opinion, and the Supreme Court’s decision is an example of well thought out application of the Eight Amendment. The end result, a logical new precedent to be applied in an ever evolving process of justice as it relates to the incarceration and the legal rights of minors.
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