Editing Life imprisonment (section)

===United States===
{{Main|Life imprisonment in the United States}}

In 2011, the [[Supreme Court of the United States]] ruled that sentencing minors to life without parole, automatically (as the result of a statute) or as the result of a judicial decision, for crimes other than intentional homicide, violated the [[Eighth Amendment to the United States Constitution|Eighth Amendment]]'s ban on "[[Cruel and unusual punishment|Cruel and unusual punishments]]", in the case of ''[[Graham v. Florida]]''.<ref>{{cite news |first=David G. |last=Savage |url=https://www.latimes.com/archives/la-xpm-2010-may-17-la-na-court-juveniles-20100518-story.html |title=Supreme Court Restricts Life Sentences Without Parole for Juveniles |work=Los Angeles Times |date=17 May 2010 |access-date=17 April 2014 |url-status=live |archive-url=https://web.archive.org/web/20131215004114/http://articles.latimes.com/2010/may/17/nation/la-na-court-juveniles-20100518 |archive-date=15 December 2013 |df=dmy-all }}</ref>
[[File:Burton Phillips.jpg|thumb|Mugshot of [[Burton Phillips]], sentenced to life imprisonment for bank robbery, 1935]]
''Graham v. Florida'' was a significant case in juvenile justice. In [[Jacksonville, Florida|Jacksonville]], Florida, Terrence J. Graham tried to rob a restaurant along with three adolescent accomplices. During the robbery, one of Graham's accomplices had a metal bar that he used to hit the restaurant manager twice in the head. Once arrested, Graham was charged with attempted armed robbery and armed burglary with assault/battery. The maximum sentence he faced for these charges was life without the possibility of parole, and the prosecutor wanted to charge him as an adult. During the trial, Graham pleaded guilty to the charges, resulting in three years of probation, one year of which had to be served in jail. Since he had been awaiting trial in jail, he already served six months and, therefore, was released after six additional months.<ref name="Drinan, C.H. 2012">Drinan, C. H. (2012, March). "''Graham'' on the Ground". ''Washington Law Review'', 87(1), 51–91. Criminal Justice Abstracts. Retrieved 28 October 2012.</ref>

Within six months of his release, Graham was involved in another robbery. Since he violated the conditions of his probation, his probation officer reported to the trial court about his probation violations a few weeks before Graham turned 18 years old. It was a different judge presiding over his trial for the probation violations a year later. While Graham denied any involvement in the robbery, he did admit to fleeing from the police. The trial court found that Graham violated his probation by "committing a home invasion robbery, possessing a firearm, and associating with persons engaged in criminal activity",<ref name="Drinan, C.H. 2012"/> and sentenced him to 15 years for the attempted armed robbery plus life imprisonment for the armed burglary. The life sentence Graham received meant he had a life sentence without the possibility of parole, "because Florida abolished their parole system in 2003".<ref name="Drinan, C.H. 2012"/>

Graham's case was presented to the [[Supreme Court of the United States]], with the question of whether juveniles should receive life without the possibility of parole in non-homicide cases. The Justices eventually ruled that such a sentence violated the juvenile's 8th Amendment rights, protecting them from punishments that are disproportionate to the crime committed,<ref name="Drinan, C.H. 2012"/> resulting in the abolition of life sentences without the possibility of parole in non-homicide cases for juveniles.

In 2012, the Supreme Court ruled in the case of ''[[Miller v. Alabama]]'' in a 5–4 decision and with the majority opinion written by Associate Justice [[Elena Kagan]] that mandatory sentences of life in prison without parole for juvenile offenders are unconstitutional. The majority opinion stated that barring a judge from considering mitigating factors and other information, such as age, maturity, and family and home environment violated the [[Eighth Amendment to the United States Constitution|Eighth Amendment]] ban on cruel and unusual punishment. Sentences of life in prison without parole can still be given to juveniles for aggravated first-degree murder, as long as the judge considers the circumstances of the case.<ref>{{cite news |date=25 June 2012 |publisher=Catholic News Service |title=Court bars mandatory life without parole for youths, rejects cross case |url=http://www.catholicnews.com/data/briefs/cns/20120625.htm#head5 |archive-url=https://archive.today/20130630010000/http://www.catholicnews.com/data/briefs/cns/20120625.htm |url-status=dead |archive-date=30 June 2013 |access-date=17 April 2014}}</ref><ref>{{Cite news|url=https://www.nytimes.com/2012/06/26/us/justices-bar-mandatory-life-sentences-for-juveniles.html|title=Court Bars Mandatory Life Terms for Juveniles in Murders|last1=Liptak|first1=Adam|date=2012-06-25|work=The New York Times|access-date=2017-05-12|last2=Bronner|first2=Ethan|issn=0362-4331|url-status=live|archive-url=https://web.archive.org/web/20170527220331/http://www.nytimes.com/2012/06/26/us/justices-bar-mandatory-life-sentences-for-juveniles.html|archive-date=27 May 2017|df=dmy-all}}</ref>

In 2016 the Supreme Court ruled in the case of ''[[Montgomery v. Louisiana]]'' that the rulings imposed by ''[[Miller v. Alabama]]'' were to apply retroactively, causing a substantial amount of appeals to decade-old sentences for then-juvenile offenders. 

In 2021, the Supreme Court ruled in ''[[Jones v. Mississippi]]'' that sentencers are not required to make a separate finding of the defendant to be "permanently incorrigible" prior to sentencing a juvenile to life without parole.