Henry v. State

Summary

The Florida Supreme Court held that Graham v. Florida applies to lengthy aggregate term-of-years sentences imposed on juvenile nonhomicide offenders when those sentences do not provide a meaningful opportunity for release based on demonstrated maturity and rehabilitation. The court concluded that Henry’s aggregate ninety-year sentence was unconstitutional because it would require imprisonment until he was nearly ninety-five years old. The court quashed the Fifth District Court of Appeal’s decision and remanded for resentencing.

Holdings

1. Graham applies when a juvenile nonhomicide offender receives a term of imprisonment that effectively ensures incarceration for life or otherwise denies a meaningful opportunity for release based on demonstrated maturity and rehabilitation; the rule is not limited to sentences formally labeled life imprisonment.
2. Henry's aggregate ninety-year sentence is unconstitutional under Graham because it requires him to remain imprisoned until he is at least nearly ninety-five years old and does not afford a meaningful opportunity for release during his natural life based on demonstrated maturity and rehabilitation.
3. Henry must be resentenced in light of the 2014 juvenile sentencing legislation enacted by the Florida Legislature.

Questions Presented

1. Whether Graham v. Florida's Eighth Amendment rule applies to lengthy aggregate term-of-years sentences imposed on juvenile nonhomicide offenders, even when the sentence is not formally denominated life imprisonment.
2. Whether Henry's aggregate ninety-year sentence violates the Eighth Amendment because it does not provide a meaningful opportunity for release based on demonstrated maturity and rehabilitation.
3. What relief is appropriate after determining that the sentence is unconstitutional.

Disposition

quashed