We argued that mandatory life sentences imposed on children are disproportionate and therefore unconstitutional under the Eighth Amendment. Such sentences are incompatible with the penological goals of deterrence, retribution and rehabilitation.
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.
We argued that Maryland's parole system is an unconstitutional ad hoc executive clemency system which fails to provide a "meaningful opportunity to obtain release" to youth sentenced to life or life equivalent terms.
We argued that juvenile adjudications are insufficient "to alone sustain proof beyond a reasonable doubt of an element of [an adult felony]" because it contradicts the rehabilitative purpose of Ohio's juvenile justice system.