I will be reviewing the case of Graham v. Florida, which was a decision by the Supreme Court in 2010 involving life sentencing of juvenile offenders that committed offenses other than homicide. I chose this case not only because it is one of a few landmark cases that paved the way for how juveniles are sentenced today, but also because it brought about a discussion of psychology in terms of its impact on youth offenders, which as a student of forensic psychology and criminal justice, is a subject I have a great deal of interest in. From a psychological standpoint, there are core developmental differences between the brain of a juvenile versus an adult, and in my opinion, I feel that they are significant enough to warrant discussion and action on how to handle juvenile justice appropriately.
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The case of Graham v. Florida involved Terrance Jamar Graham and the state of Florida for crimes he committed under the age of 18 and the subsequent sentences he received. In 2003, when Graham was 16 years old, he and three other adolescents made an attempt to rob a restaurant. One of the members involved worked at the restaurant and ensured the back door remained unlocked around the time the restaurant was due to close. Graham and one other person entered the restaurant through the back door and the individual he was with hit the manager in the head with a metal bar twice, eventually requiring the manager to get stitches for his injury. The manager yelled at Graham and the second individual, causing them to run out prior to stealing anything and depart the area in a car that was waiting for them. Graham was subsequently arrested for the attempted robbery and his prosecutor chose to charge him as adult. When he was charged for armed burglary with assault and an attempted armed robbery, the maximum sentence was life imprisonment without any chance of parole. He pleaded guilty to both charges, and his plea agreement was ultimately accepted and he received concurrent 3-year terms of probation, with the first third of it spent in jail. Approximately 6 months after his release from jail, and still under the age of 18, he was arrested again for another robbery. Graham and two accomplices forcibly entered a house and held two men at gunpoint while they searched the house for money. That night, Graham was signaled to stop driving by a police officer, which he ignored and sped away from, resulting in a crash. He was then apprehended and three guns were found in his possession. As a result, in 2006, he was again sentenced to life in prison (Graham v. Florida, 2010).
- What was the specific legal issue to be decided?
As a result of his sentence, Graham challenged his life imprisonment under the idea that it was in violation of the Eighth Amendment of the Constitution, which states that cruel or unusual punishments shall not be carried out. Specifically, the issue to be decided upon then became if a life sentence without parole for a juvenile could be seen as cruel and unusual and therefore excessive by terms of the Constitution (Momose, 2010).
The Supreme Court decided that life sentences without the possibility of parole for offenses other than homicide violated the Eighth Amendment and were therefore unconstitutional. The ruling did not outright ban life sentences under these conditions, but instead, ruled that there must be an opportunity to obtain release should the individual demonstrate that they have matured and are able to be rehabilitated. In other words, a life without parole sentence cannot be issued, but the same offender who was unable to be issued a life without parole sentence could still be imprisoned for life if they did not demonstrate their suitability for release. The overall rationale for the decision was that juveniles have limited culpability for their actions, are still developing in a psychological capacity, and have an increased capacity to change as they mature, leading to the necessity of affording them the opportunity to be released with the chance for parole (Momose, 2010).
In the analysis of the case, the Supreme Court looked back on a previous case of a similar nature, the 2005 case of Roper v. Simmons, which sought to decide if the death penalty for juveniles was in violation of the Eighth Amendment. In Roper, it was determined that juveniles had a high propensity to have qualities that led them to make decisions and actions that did not consider second or third order effects. Similarly, the lack of maturity and irresponsibility seen in juveniles is the precise reason that nearly all states do not enable juveniles to vote, serve on jury duty, or marry on their own accord, implying that crime needs to be analyzed in somewhat of the same manner. It was also considered that juveniles are very susceptible to peer pressure and that their character is not fully formed, leading to their behavior being more malleable and transitory than that of an adult, and therefore more likely to be able to be rehabilitated. The Graham Court found no evidence that disputed these findings from the Roper Court, and actually further explored new psychological developments on differences between juvenile and adult brains that supported the claim that discipline should be approached differently between the two (Berkheiser, 2011).
References
- Berkheiser, M. (2011). Death Is Not so Different After All: Graham V. Florida and the Court’s “Kids Are Different” Eighth Amendment Jurisprudence. Vermont Law Review, 36(1), 1–62. Retrieved from https://search-ebscohost-com.ezproxy.snhu.edu/login.aspx?direct=true&db=edshol&AN=edshol.hein.journals.vlr36.4&site=eds-live&scope=site
- Graham v. Florida, 560 U.S. 48 (2010)
- Momose, M. (2010). A case for hope: Examining Graham v. Florida and its implications for Eighth Amendment jurisprudence. University of Hawai’i Law Review, 33(1), 391-416. Retrieved from https://search-ebscohost-com.ezproxy.snhu.edu/login.aspx?direct=true&db=edshol&AN=edshol.hein.journals.uhawlr33.23&site=eds-live&scope=site
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