Malvo v. State

Lee Boyd Malvo v. State of Maryland No. 29, September Term, 2021. Criminal Procedure – Constitutional Law – Sentencing of Juvenile Offender – Homicide. Recent Supreme Court decisions have held that the Eighth Amendment to the United States Constitution does not permit a sentence of life without parole for a juvenile offender convicted of homicide if the sentencing court determines that the offender’s crime was the result of transient immaturity, as opposed to permanent incorrigibility. That constitutional constraint applies retroactively. However, a court that imposes a sentence in a…