Graham v. Florida

Following is the case brief for Graham v. Florida, 560 U.S. 48 (2010).

Case Summary of Graham v. Florida:

  • Petitioner Graham committed two robbery-type offenses before he was 18 years old.  He was ultimately sentenced to life without parole.
  • Graham challenged his sentence as violative of the Eighth Amendment’s prohibition of cruel and unusual punishment.  The Florida state courts denied Graham relief.
  • The U.S. Supreme Court reversed.  It held that a sentence of life without parole for a non-homicide juvenile offender is cruel and unusual in violation of the Eighth Amendment.

Graham v. Florida Case Brief

Statement of the Facts:

In 2003, when Petitioner Graham was 16 years old, he attempted to rob a local barbecue restaurant with several accomplices.  He pleaded guilty to robbery charges and was sentenced to 3 years probation, 12 months of which were served in county jail.

Shortly after his release from jail, Graham was arrested for a home-invasion robbery.  He pleaded guilty to a violation of his probation based on the circumstances of the second incident.  The trial court, finding that Graham was given a chance to turn his life around and chose not to, sentenced Graham to life in prison.  He had no possibility of parole because Florida abolished its parole system in 2003.

Procedural History:

Graham filed a motion in trial court, challenging his sentence based on the Eighth Amendment. The trial court denied the motion, and the First District Court of Appeal in Florida affirmed that denial.  The Florida Supreme Court denied review.  The U.S. Supreme Court granted certiorari.

Issue and Holding:

Does the Constitution allow a criminal juvenile offender to be given a life-without-parole sentence for a non-homicide crime?  No.

Judgment:

The judgment of the Florida First District Court of Appeal is reversed, and the matter remanded for further proceedings consistent with the Court’s opinion.

Rule of Law or Legal Principle Applied:

Sentencing a juvenile offender to life in prison without parole for a non-homicide offense is a violation of the Eighth Amendment’s prohibition of cruel and unusual punishment.

Reasoning:

Proportionality is the touchstone of an Eighth Amendment inquiry into the validity of a criminal sentence.  Cases addressing proportionality fall into two general types:  (i) those that look at all surrounding circumstances to determine if a sentence is unconstitutionally excessive; and (ii) those that use categorical rules to define Eighth Amendment parameters.  The second type is appropriate in the present case.

  • Categorial approach regarding juvenile offenders.

The initial inquiry in the categorical approach takes into account contemporary values.  Looking at actual sentencing data (rather than current sentencing legislation), it is clear that life-without-parole sentences for juveniles are extremely rare in the U.S.

In addition, the culpability of offenders must be taken into account.  The Court has acknowledged in past cases that juveniles lack the maturity and sense of responsibility of adults, thereby lessening their culpability.  Furthermore, juveniles are more able to be rehabilitated, particularly those who did not commit murder.

  • Penological reasons for punishment do not support Graham’s sentence.

While retribution, deterrence, and incapacitation may be legitimate reasons to punish, they do not support Graham’s harsh sentence.  Separating Graham from society for a period of time is appropriate to stem his escalating criminal conduct.  However, it does not follow that he is a threat to society for the rest of his life.  His limited culpability by being a juvenile coupled with his harsh sentence lead to the conclusion that Graham’s sentence is cruel and unusual.

  • Categorial rule for non-homicide juvenile offenders is fair and agrees with world values.

Finally, the Court’s categorical rule here — that non-homicide juvenile offenders should not receive a sentence of life without parole — gives such juvenile offenders the chance to show maturity and reform.  Such a categorial rule also comports with sentencing practices throughout the world.

Concurring and Dissenting Opinions:

Concurring Opinion (Stevens):

Justice Thomas’s static view of the Eighth Amendment fails to recognize that times change.  The evolving standards of decency have played a part in the Court’s Eighth Amendment jurisprudence for over a century, and the standards of decency will continue to evolve.

Concurring Opinion (Roberts):

Some crimes are so heinous, and some juvenile offenders so culpable, that a life-without-parole sentence for a juvenile may be constitutionally appropriate.  While Graham’s case is not one in which life without parole is appropriate, the Court should not have established a categorical rule that now will apply to far different cases.

Dissenting Opinion (Thomas):

The Court is replacing its moral judgment for that of the American citizens who, through their legislatures, have stated that it is not immoral for a juvenile offender in a non-homicide case to receive a life-without-parole sentence.

Dissenting Opinion (Alito):

The Court’s opinion does not rule out a sentence for a term of years without the possibility of parole for a juvenile offender.  The Court need reach a decision on an as-applied proportionality challenge because Graham did not put it before the Court.

Significance:

Graham v. Florida stands as the midpoint in the Court’s evolution on the Eighth Amendment between its decision to ban capital punishment for juveniles in Roper v. Simmons 543 U.S. 551 (2005), and its decision (two years after this case was decided) to ban life-without-parole sentences for juvenile homicide offenders in Miller v. Alabama, 567 U.S. Supreme Court (2012).

Student Resources:

https://supreme.justia.com/cases/federal/us/560/08-7412/opinion.html

https://www.oyez.org/cases/2009/08-7412

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