that decision. Id. The United States Supreme Court granted certiorari and reversed, holding that a life sentence without the possibility of parole imposed on a juvenile offender convicted of a non-homicide offense was categorically unconstitutional. Id. Examining statistics from the several states regarding the number of jurisdictions (39) that allowed a juvenile convicted of a non-homicide offense to be sentenced to life imprisonment without parole, and the rarity in which the sentence is imposed (123 juveniles serving the sentence for non-homicide crimes in the United States), the Supreme Court determined that there is a national consensus against the sentencing practice. Id. at 2023-26. Relying on its findings in Roper v. Simmons, 543 U.S. 551, 125 S.Ct. 1183, 161 L.Ed.2d 1 (2005) (<HOLDING>), it found that “because juveniles have
holding the death penalty unconstitutional for defendants under age eighteen at the time of the crime holding that the death penalty was categorically prohibited for juvenile offenders holding that the death penalty is unconstitutional as applied to juvenile defendants holding that leaning towards the death penalty is not the same as an automatic vote for the death penalty holding the death penalty unconstitutional for mentally retarded defendants