People v. Caballero, 55 Cal. 4th 262

Sixteen-year-old Caballero was convicted of three counts of attempted murder, with firearm enhancements, and sentenced to a total of 110 years to life.
The Court of Appeal affirmed; the People argued Graham does not prohibit such sentences for attempted murder and for consecutive terms.
Graham v. Florida held that juveniles cannot be sentenced to life without parole for nonhomicide offenses, requiring a meaningful opportunity for release.
Miller v. Alabama extended Graham to homicide cases, forbidding mandatory life without parole for juveniles, while clarifying Graham’s nonhomicide rule applies to all such cases.
This case asks whether a 110-year-to-life term for nonhomicide offenses committed by a juvenile violates Graham, given parole eligibility outside the juvenile’s life expectancy.
The court concludes that, under Graham and Miller, a de facto life sentence for a juvenile nonhomicide offense with parole eligibility beyond the juvenile’s life expectancy is cruel and unusual.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does a 110-to-life sentence for a juvenile nonhomicide offense violate Graham?	Caballero argues the sentence is a de facto life without parole barred by Graham.	People contend each component term is permissible if parole is possible within a lifetime.	Yes; violates Graham's bar on meaningful opportunity to obtain release.
Does Miller's framework apply to nonhomicide juveniles to bar such sentences overall?	Graham’s flat ban extends to this nonhomicide case via Miller’s reasoning.	Miller restricts the ban to homicide cases; nonhomicide remains governed by Graham's categorical rule.	Yes; Miller supports treating the sentence as a Graham violation for nonhomicide juveniles.
Is the sentence a permissible term of years or the functional equivalent of life without parole?	The total term is the functional equivalent of life without parole.	Convictions are separately justified by valid terms with parole opportunities.	No; the combined effect is a de facto life without parole for a juvenile.
Should the case be remanded for resentencing to comply with Graham/Miller?	Remand with guidance for a constitutionally compliant sentence is appropriate.	Legislature should create a mechanism; remand with directives is proper here.	Remand for resentencing consistent with Graham/Miller.

Graham v. Florida, 560 U.S. 48 (U.S. 2010) (flat ban on life without parole for juvenile nonhomicide offenses; meaningful opportunity for release)
Miller v. Alabama, 567 U.S. 460 (U.S. 2012) (extends Graham to homicide cases; cannot impose mandatory life without parole for juveniles)
Roper v. Simmons, 543 U.S. 551 (U.S. 2005) (juveniles have diminished culpability and greater potential for reform)
Kennedy v. Louisiana, 554 U.S. 407 (U.S. 2008) (juvenile culpability and irreversibility considerations in sentencing)
Coker v. Georgia, 433 U.S. 584 (U.S. 1977) (death, irreversibility considerations for serious crimes)