of contract, our ruling is unaffected. As discussed in Part IV(B)(2) of this opinion, plaintiffs have failed to demonstrate that public school employees have a contractual right to continue accruing pension benefits at any specific rate. By the same analysis, the state could not have breached a contract by enacting 2012 PA 300 if the alleged contract did not exist in the first place. 3 Although the Court of Appeals also held in AFT Mich I, 297 Mich App at 621, that 2010 PA 75 violated the Takings Clauses of the Michigan and United States Constitutions, Const 1963, art 10, § 2 and US Const, Ams V and Xiy plaintiffs have clearly raised before this Court a challenge under those constitutional provisions. Therefore, we have no need to infer from their reference to 485 NW2d 866 (1992) (<HOLDING>), with Harmelin v Michigan, 501 US 957; 111 S
holding life in prison without the possibility of parole was not cruel and unusual punishment for juvenile convicted of murder holding that a mandatory life sentence without the possibility of parole for possession of 650 or more grams of cocaine is so grossly disproportionate that it violates the prohibition of cruel or unusual punishment in const 1963 art 1  16 holding that a mandatory life sentence for cocaine possession is not unusual in the constitutional sense 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 a life sentence without parole for possession of 650 grams of cocaine base did not violate the eighth amendment