Terrance Graham was 16 years old when he committed armed burglary in Florida. A judge sentenced him to life without parole -- and because Florida had abolished its parole system, Graham had zero chance of release except through a governor's clemency. In 2010, the Supreme Court ruled in Graham v. Florida that sentencing a juvenile to die in prison for a non-homicide crime violates the Eighth Amendment's ban on cruel and unusual punishment.
Justice Anthony Kennedy wrote that children are constitutionally different from adults: their brains are still developing, they are more susceptible to peer pressure, and their characters are not yet fixed. At the time of the ruling, 129 people across the country were serving life-without-parole sentences for non-homicide crimes they committed as minors -- 77 of them in Florida alone. The Court did not require states to guarantee eventual release, but said they must provide "some realistic opportunity to obtain release" during a juvenile's lifetime. Two years later, in Miller v. Alabama (2012), the Court extended this reasoning and banned mandatory life-without-parole sentences for juveniles even in homicide cases, requiring judges to consider each young defendant's individual circumstances before imposing the harshest sentence.