to the lifetime post-release supervision portion of her sentence can only be addressed under the second classification — as a purely legal, categorical proportionality challenge. The United States Supreme Court has identified three subcategories of categorical constitutional challenges: (1) those considering the nature of the offense, (2) those considering the characteristics of the offender, and (3) those that combine the first two subcategories by considering a particular iype of sentence as it applies to an entire class of offenders who have committed a range of crimes. Graham, 560 U.S. at 60-61. Reed’s categorical constitutional argument asserts that the Eighth Amendment categorically prohibits the imposition of lifetime postrelease for a sex offense in which the offe 1079 (1976) (<HOLDING>). Reed’s arguments regarding the nature of the
holding an unappealed ruling is the law of the case and cannot be later challenged holding that a sentencing decision will be affirmed if challenged factor is permissible and other factors are not challenged holding state of the law must be determined at time of challenged action holding that the injury must be fairly traceable to the challenged action to be redressable by the court holding that unconstitutional government action can only be challenged by a person directly affected it cannot be challenged by one invoicing the rights of third parties