on the basis of an otherwise constitutional statutory aggravator. ¶ 32 Even if we assume Graham supplies the proper analysis for challenging an aggravator, such a challenge fails here. Under Graham, a court “considers ‘objective indicia of society’s standards, as expressed in legislative enactments and state practice’ to determine whether there is a national consensus against the sentencing practice at issue.” 130 S.Ct. at 2022 (quoting Roper v. Simmons, 543 U.S. 551, 572, 125 S.Ct. 1183, 161 L.Ed.2d 1 (2005)). In the past decade, the Supreme Court has used this approach in three death penalty eases. See Kennedy v. Louisiana, 554 U.S. 407, 446, 128 S.Ct. 2641, 171 L.Ed.2d 525 (2008) (concluding the death penalty cannot be imposed for rape); Roper, 543 U.S. at 578, 125 S.Ct. 1183 (<HOLDING>); Atkins v. Virginia, 536 U.S. 304, 321, 122
holding the death penalty unconstitutional for defendants under age eighteen at the time of the crime holding that the execution of individuals who were under 18 years of age at the time they committed capital crimes violates the eighth and fourteenth amendments to the united states constitution recognizing that within the world community the imposition of the death penalty for crimes committed by mentally retarded offenders is overwhelmingly disapproved holding that mandatory life imprisonment without parole for those under the age of eighteen at the time of their crimes violates eighth amendment holding the eighth and fourteenth amendments forbid imposition of the death penalty on offenders who were under the age of eighteen when their crimes were committed