Argued that Petitioner's sentence is the equivalent of life without parole because Missouri law requires him to serve a minimum of 92 years before becoming parole-eligible. This sentence therefore violates the United States Supreme Court’s ruling in Graham v. Florida, which held that juvenile offenders cannot be sentenced to life for non-homicide offenses without a meaningful and realistic opportunity for re-entry into society prior to the expiration of their sentence.
Argued that Petitioner Bunch's sentence is unconstitutional pursuant to the United States Supreme Court's ruling in Graham v. Florida, which held that juvenile offenders cannot be sentenced to life without parole without a meaningful and realistic opportunity to re-enter society prior to the expiration of their sentences for non-homicide offenses.
Juvenile Law Center’s brief argues that the mandatory sentence of life in prison without the possibility of parole imposed on a 16-year-old is a disproportionate punishment under the U.S. and Massachusetts Constitutions.
Argued that due process is violated when a judge uses his independent knowledge about a youth’s child welfare history and involvement, including past misconduct, as evidence to adjudicate the youth delinquent in the juvenile justice system.
Argued that a sentence of 110 years to life (three consecutive life-terms) for a non-homicide offense committed as a juvenile violates the United States Supreme Court’s ruling in Graham v. Florida.
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