People v. Contreras

The California Supreme Court clarified that a sentence need not exceed life expectancy to deprive a juvenile nonhomicide offender of the requisite meaningful opportunity for release based on demonstrated maturity and rehabilitation, remanding a 50-year and a 58-year sentence for resentencing.

State ex rel. Carr v. Wallace

The Missouri Supreme Court has granted relief as to a life-without-parole-for-50-years sentence, explaining that the sentence was “the harshest penalty other than death available under a mandatory sentencing scheme,” and that the jury had no opportunity to consider youth.

State v. Ramos

The Washington Supreme Court applied Miller to an 80-year aggregate sentence, explaining that Miller applies anytime a juvenile offender might be sentenced to die in prison without a meaningful opportunity for early release based on rehabilitation, whether the sentence is for a single crime or an aggregate sentence for multiple crimes.

State v. Zuber and Comer

New Jersey Supreme Court held that defendants, sentenced to lengthy, aggregate term-of-year periods of incarceration for homicide and nonhomicide crimes, were entitled to resentencing because the sentences at issue were sufficiently lengthy to trigger Miller’s protections

State v. Moore

Ohio Supreme Court determined that defendant’s 112-year aggregate sentence for nonhomicide crimes—pursuant to which he would be eligible for release after 77 years, at age 92—violated Graham’s prohibition on juvenile life without parole for nonhomicide offenders because it denied a meaningful chance to demonstrate rehabilitation and obtain release.

People v. Reyes

Illinois Supreme Court concluded that Miller applies to mandatory term-of-years sentence, imposed for offenses committed during a single course of conduct, that cannot be served in one lifetime (here, a 97-year sentence with earliest possible release after 80 years).

Henry v. State

Florida Supreme Court held that Graham applies to lengthy term-of-years sentences, including aggregate sentences, that deprive the juvenile offender of a meaningful opportunity to obtain release.

State v. Riley

Connecticut Supreme Court held that juvenile offender sentenced to 100 years in discretionary regime entitled to resentencing because sentencing court did not give “due mitigating weight” to the characteristics and circumstances of youth.

State v. Null

Juvenile offender sentenced to a mandatory 75-year sentence with no parole eligibility for 52.5 years entitled to resentencing under Miller and the Iowa Constitution.

State v. Pearson

Iowa Supreme Court remanded sentence of 50 years’ incarceration with parole eligibility after 35 years, imposed for nonhomicide crimes, for an individualized sentencing and consideration of youth in line with Miller.

State v. Boston

Nevada Supreme Court concluded that Graham applies to lengthy, term-of-year sentences, including aggregate sentences, that are the functional equivalent of life without parole.

State ex rel. Alden Morgan v. State

Louisiana Supreme Court held that a 99-year sentence without the possibility of parole contravened Graham’s requirement of a meaningful opportunity to obtain release and is illegal (but distinguished aggregate term-of-year sentences).

Bear Cloud v. State

Juvenile offender ineligible for parole for 45 years entitled to resentencing under Miller; court must weigh the entire sentencing package in light of the mitigating factors of youth.