into the “grossly disproportionate” analysis, this type of constitutional argument does not lend itself to a facial challenge. To state that the imposition of a life sentence without parole on a juvenile is per se violative of the Eighth Amendment, a court would have to reject existing Supreme Court precedent regarding the factual inquiry required in such a case. As such, it does not appear that the United States Supreme Court contemplated this type of per se prohibition to a specific term of years. In addition to t 946-47 (1989) (invalidating the use of a true life sentence imposed on a thirteen-year-old convicted of killing his molester after considering appellant’s age and mental condition at the time of the killing); Workman v. Commonwealth, 429 S.W.2d 374, 377-78 (Ky.Ct.App.1968) (<HOLDING>); People v. Dillon, 34 Cal.3d 441, 194
holding that an effective life sentence of fortyfive years for seconddegree forgery was excessive and that a life sentence was cruel and unusual in violation of the eighth amendment holding that 25 years to life sentence under the california three strikes law did not violate the eighth amendments prohibition on cruel and unusual punishment 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 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 that the imposition of a life sentence for failure to register as a sex offender constituted cruel and unusual punishment because the sentence was so harsh in comparison to the crime