Graham v. Florida

Facts

The Defendant, Terrance Graham, was born to parents who used drugs. In elementary school, he was diagnosed with attention deficit hyperactivity disorder. At the age of 9, the Defendant began drinking and at the age of 13 he began using tobacco.

At the age of 16, the Defendant and three other youths attempted to rob a restaurant. The charges against the Defendant were armed burglary with assault or battery and attempted armed robbery. Armed burglary with assault or battery was a first-degree felony carrying a maximum penalty of life imprisonment without the possibility of parole and attempted armed robbery was a second-degree felony carrying a maximum penalty of 15 years imprisonment. The Defendant pleaded guilty to both charges under a plea agreement. The court  sentenced the Defendant to three years probation.

Roughly six months later, the Defendant was once more arrested. The Defendant and two others named Bailey and Lawrence participated in a home invasion robbery during which they held a couple of men at gunpoint while ransacking the house to look for cash. Additionally later that same night, the three attempted a second robbery during which Bailey was shot. A detective asked the Defendant how many other robberies he had been involved in other than the ones that night to which the Defendant replied, “two or three.” The events occurred 34 days shy of the Defendant’s 18th birthday.

The trial court held hearings on the Defendant’s probation violations. It found that the Defendant violated his probation by committing home invasion robbery, by possessing a firearm, by associating with persons engaged in criminal activity, and fleeing arrest. The trial court found the Defendant guilty of the earlier armed burglary and attempted armed robbery charges. The trial court sentenced the Defendant to the maximum sentence authorized by law on each charge which was life imprisonment for the armed burglary and 15 years for the attempted armed robbery. Since Florida abolished its parole system, a life sentence gives a defendant no possibility of release unless granted executive clemency.

The Defendant challenged his sentence under the Eighth Amendment.