Leighdon Henry v. State of Florida, 175 So. 3d 675

At 17, Leighdon Henry was convicted of multiple nonhomicide felonies and originally sentenced to life plus 60 years; after a Rule 3.800(b)(2) motion, he was resentenced to an aggregate 90-year term.
Henry challenged his aggregate term-of-years sentence under Graham v. Florida, which held that juvenile nonhomicide offenders may not be sentenced to life without parole and must have a meaningful opportunity for release.
The Fifth District affirmed Henry’s 90-year aggregate sentence, reasoning Graham applies only to literal life-without-parole sentences, not lengthy term-of-years sentences.
The Florida Supreme Court granted review to decide whether Graham’s Eighth Amendment rule applies to lengthy term-of-years sentences that functionally deny a juvenile a meaningful opportunity for release.
The Court concluded Graham applies when a juvenile’s sentence forecloses a meaningful opportunity to obtain release during the juvenile’s natural life and found Henry’s 90-year aggregate sentence unconstitutional.
The Court quashed the Fifth District, remanded for resentencing consistent with Graham and Florida’s post-2014 juvenile sentencing legislation.

Issue	Henry's Argument	State's Argument	Held
Whether Graham v. Florida applies to aggregate term-of-years sentences that are not labeled "life"	Graham applies because any sentence that prevents a meaningful opportunity for release violates the Eighth Amendment	Graham is limited to literal life-without-parole sentences and does not reach term-of-years sentences	Graham applies to term-of-years sentences if they deny a meaningful opportunity for release; Henry's 90-year term is unconstitutional
Remedy/Relief required when sentence violates Graham	Resentencing or relief to provide meaningful opportunity for release consistent with Graham	Sentence should be upheld unless labeled life-without-parole; if invalid, limited remand	Case remanded for resentencing under Graham and in light of 2014 juvenile sentencing legislation

Graham v. Florida, 560 U.S. 48 (2010) (categorical rule: juvenile nonhomicide offenders cannot be sentenced to life without parole; must have meaningful opportunity for release)
Miller v. Alabama, 132 S. Ct. 2455 (2012) (juvenile status requires individualized sentencing consideration; mandatory life-without-parole schemes unconstitutional)
Roper v. Simmons, 543 U.S. 551 (2005) (juveniles have diminished culpability and greater capacity for change)
Harmelin v. Michigan, 501 U.S. 957 (1991) (life without parole characterized as among the harshest penalties)
Henry v. State, 82 So. 3d 1084 (Fla. 5th DCA 2012) (district court decision holding Graham inapplicable to term-of-years sentences)