principle emerges as ‘clearly established’ ” — namely, that a “gross disproportionality principle is applicable to sentences for terms of years.” Id. (quoting 28 U.S.C. § 2254(d)(1)). Adaway, 902 So.2d at 748-49 (emphasis added). Further, in Solem v. Helm, 463 U.S. 277, 292, 103 S.Ct. 3001, 77 L.Ed.2d 637 (1983), the United States Supreme Court announced objective criteria to be used in a “grossly disproportionate” consideration and looked specifically at: (1) the gravity of the offense and the harshness of the penalty; (2) the sentences imposed on other criminals in the same juris diction; and (3) the sentences imposed for commission of the same crime in other jurisdictions. Because the weight of applicable precedent requires a fact-specific inquir 390, 668 P.2d 697, 726-27 (1983) (<HOLDING>). Additionally, several courts have upheld the
holding that a mandatory sentence of life in prison without the possibility of parole for a juvenile convicted of firstdegree murder is not cruel and unusual punishment in violation of the united states and pennsylvania constitutions holding that life sentence imposed for kidnapping with bodily injury was not cruel and unusual even if victims injuries were minor holding that the imposition of a true life sentence on a minor convicted of felony murder was cruel and unusual based on the specific circumstances surrounding the offense holding life in prison without the possibility of parole was not cruel and unusual punishment for juvenile convicted of murder holding that the imposition of a true life sentence on two fourteenyearold offenders for committing the crime of rape was violative of the eighth amendment prohibition on cruel and unusual punishment