Carter, Bowie, McCullough v. State

It has been said that "mercy without justice is the mother of dissolution; justice without mercy is cruelty." 1 A sentence of life in prison without parole may be just for certain adult offenders, but the Eighth Amendment's proscription against cruel and unusual punishments precludes that sentence for a juvenile offender unless the defendant is an incorrigible murderer. Although there need not be a guarantee of release on parole, a sentence imposed on a juvenile offender must provide "some meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation." 2

In this…