State v. Long, 8 N.E.3d 890 (Ohio 2014) – Juvenile defendant (age 17 at time of crimes) was convicted of aggravated murder (2 counts), felonious assault (3 counts), having a weapon while under disability (2 counts), and various weapons offenses. He was sentenced to consecutive terms of LWOP (murder) plus 19 years (other offenses), to run consecutively. The state’s sentencing statute at the time, R.C. 2929.03(A), allowed the trial court to exercise its discretion when sentencing for aggravated murder by imposing LWOP or life with parole eligibility after 20, 25, or 30 years. The Ohio Supreme Court held that, based on Miller, a trial court must consider a juvenile offender’s youth as a mitigating factor before imposing an LWOP sentence. Further, the record must reflect that the court specifically considered the juvenile offender’s youth as a mitigating factor at sentencing when imposing LWOP. Although Miller does not require that specific findings related to youth be made on the record, “[b]ecause the trial court did not separately mention that Long was a juvenile when he committed the offense, we cannot be sure how the trial court applied this factor.” Additionally, “because [an LWOP] sentence implies that rehabilitation is impossible, when the court selects this most serious sanction, its reasoning for the choice ought to be clear on the record.” The court noted: “[F]or juveniles . . . a sentence of [LWOP] is the equivalent of a death penalty. As such, it is not to be imposed lightly, for as the juvenile matures into adulthood and may become amenable to rehabilitation, the sentence completely forecloses that possibility.” (citations omitted). This sentence did not comport with the mandates of Miller. Vacated sentence and remanded to the trial court for resentencing.