Juvenile Sentence and the Eighth Amendment

In People v. Caballero (2012) 55 Cal.4th 262, the California Supreme Court considered Graham v. Florida (2010) U.S. 130 S.Ct. 2011 and Miller v. Alabama (2012) U.S. 132 S.Ct. 2455 in determining whether a juvenile's sentence violated the Eighth Amendment to the United States Constitution. In Caballero, the defendant was sentenced to 110 years to life for three counts of attempted murder; he had been 16 years old when he committed his crimes. (Id. at p. 265.) The California Supreme Court noted that, in Graham v. Florida (2010) U.S. 130 S.Ct. 2011, the United States Supreme Court ruled that the Eighth Amendment requires state courts to afford juvenile offenders a meaningful opportunity to be released based on demonstrated growth and maturity. In clarifying this standard, Graham relied on studies showing the fundamental differences between juvenile and adult minds, including behavior control, which continues to mature through late adolescence, and that juveniles are more capable of change than adults. (Caballero, supra, 55 Cal.4th at p. 266.) As the our Supreme Court further observed in Caballero: "Graham likened a life without parole sentence for nonhomicide offenders to the death penalty itself, given their youth and the prospect that, as the years progress, juveniles can reform their deficiencies and become contributing members of society." (Ibid.) In Caballero, our Supreme Court also noted that Miller reiterated Graham's focus on the "distinctive (and transitory) mental traits and vulnerabilities" of children, finding them applicable even in a robbery turned homicide situation. (See Caballero, supra, 55 Cal.4th at p. 267.) The California Supreme Court found that Miller v. Alabama (2012) U.S. 132 S.Ct. 2455 clarified Graham's "'flat ban'" on life-without-parole sentences in nonhomicide cases involving juvenile defendants, including sentences that amount to the "functional equivalent" of a term of life-without-parole sentence, as had been imposed in Caballero. (Caballero, supra, at pp. 267-268.) Based on its analysis of Miller and Graham, our Supreme Court held in Caballero that sentencing a juvenile offender for a nonhomicide offense to a specified term of years, with a parole eligibility date that falls outside the offender's own natural life expectancy, constitutes cruel and unusual punishment. (Caballero, supra, at p. 268.) The court reversed the defendant's sentence and remanded for resentencing in light of these principles.