Torrence Lawton v. State of Florida

In Graham v. Florida, 560 U.S. 48, 74-75, 130 S.Ct. 2011, 176 L.Ed.2d 825 (2010), the United States Supreme Court held that the Eighth Amendment’s prohibition on cruel and unusual punishment compels a categorical rule against sentencing a juvenile offender “to life without parole for a nonhomicide crime.” In the decision on review, the Third District read Graham as creating a homicide-case exception to this categorical rule, which would permit a juvenile to be sentenced to life without parole for a nonhomicide offense if the juvenile also committed a homicide in the same criminal episode.…