California Supreme Court Rules 110-years-to-life Sentence Imposed on a Juvenile Is Unconstitutional


In People v. Caballero, the California Supreme Court unanimously struck down the 110-years-to-life sentence imposed on Rodrigo Caballero for nonhomicide offenses when he was 16 years old. The court concluded that the sentence, which required Caballero to serve more than 100 years before being eligible for parole, denied him the opportunity to “demonstrate growth and maturity” to try to secure his release, in contravention of the U.S. Supreme Court’s decision in Graham v. Florida.

The U.S. Supreme Court in 2010 struck down life-without-parole sentences for juvenile offenders convicted of nonhomicide offenses. The Court held in Graham v. Florida that the Eighth Amendment requires the state to afford juvenile nonhomicide offenders a “meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation,” and that “[a] life without parole sentence improperly denies the juvenile offender a chance to demonstrate growth and maturity.”

The California Supreme Court followed Graham‘s reasoning yesterday, concluding that “sentencing a juvenile offender for a nonhomicide offense to a term of years with a parole eligibility date that falls outside the juvenile offender’s natural life expectancy constitutes cruel and unusual punishment in violation of the Eighth Amendment.”

The court held that, while not all juvenile offenders will earn release on parole, the state may not deprive them of that opportunity at sentencing.

Under Graham, the sentencing court must consider all mitigating circumstances in the juvenile’s crime and life, including his age at the time of the crime, his role in the offense, and his physical and mental development, so that it can impose a time when the juvenile offender will be able to seek parole from the parole board. The Board of Parole Hearings will then determine whether the juvenile offender must be released from prison “based on demonstrated maturity and rehabilitation.”

Because every case will be different, the court did not set a precise time frame for setting future parole hearings in nonhomicide cases. But it emphasized that the sentence must provide a “meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation” under Graham.