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Terrance Graham pled guilty to armed burglary with assault or battery and attempted armed robbery when he was sixteen years old. He was sentenced to prison for the rest of his life. Like Roe v. Wade made history by forcing this country to consider the morality of abortion, so too will the United States Supreme Court's decision in Graham v. Florida make history by challenging the morality of sentencing juveniles for the rest of their lives. After firmly abolishing the death penalty for all juvenile offenders under the age of eighteen, as a violation of the Eighth Amendment's Cruel and Unusual Punishment Clause, the Court has once again curbed the punishments permissible for the juvenile offender. Reaffirming that juveniles are less culpable than adults, the Court holds that life without parole is disproportionately harsh for juvenile non-homicide offenders, and is therefore cruel and unusual under the Eighth Amendment.

Standing in agreement with Graham, this Article analyzes two issues left in its wake: (1) the inconsistency in the Court's reasoning when viewed against lengthy term of year sentences, and (2) the implicit requirement to reinstate effective parole boards in light of Graham's new constitutional mandate to give juveniles a meaningful opportunity to reenter society. This Article does not suggest that juvenile offenders escape punishment for committed offenses, but rather concludes that our country acknowledges the historic impact and repercussions of Graham's central premise--juveniles are different from adults. Because of this decision, states must deal with those differences in tangible ways to give juvenile offenders hope to reenter society.