Veal v. State, 303 Ga. 18

In 2010 Robert Veal (a juvenile at the time) was convicted of malice murder and multiple related offenses arising from two armed robberies; the trial court originally imposed life without parole (LWOP) plus other consecutive life and term-of-years sentences.
On Veal’s first appeal (Veal I), the Georgia Supreme Court vacated the LWOP sentence because the trial court made no on-the-record individualized Miller factors finding that Veal was "irreparably corrupt" or permanently incorrigible, and remanded for resentencing.
At resentencing the State declined to seek LWOP and requested additional consecutive life-with-parole sentences; the trial court imposed them, yielding an aggregate sentence of eight consecutive life terms plus 60 years.
Veal argued the new aggregate sentence is a de facto LWOP (given OCGA § 42-9-39(c) parole-eligibility rules and his life expectancy) and thus required the same Miller/Montgomery individualized determination; he also invoked Graham (ban on LWOP for juveniles for nonhomicide offenses) as applied to aggregate sentences.
The Georgia Supreme Court declined to extend Miller/Montgomery beyond actual LWOP sentences and rejected Veal’s aggregate-sentence claims; it also deemed any Georgia constitutional claim abandoned for lack of briefing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Miller/Montgomery require an individualized finding before imposing an aggregate sentence that is a functional equivalent of LWOP	Veal: Miller protections apply to any juvenile sentence that, in effect, denies parole for life (de facto LWOP); court must consider youth factors before imposing aggregate life-with-parole terms that exceed life expectancy	State: Miller and Montgomery govern only actual LWOP sentences; they do not require individualized findings for aggregate life-with-parole or long term-of-years sentences	Court: Refused to expand Miller/Montgomery beyond LWOP; affirmed sentencing without Miller-style individualized finding
Whether Graham’s prohibition on LWOP for juveniles for nonhomicide offenses applies to aggregate sentences that produce de facto LWOP for nonhomicide convictions	Veal: Consecutive life terms for nonhomicide offenses produce an unconstitutional de facto LWOP in violation of Graham when aggregated	State: Graham addresses actual LWOP for nonhomicide juveniles and does not apply to aggregate life-with-parole sentences	Court: Rejected the Graham-based challenge for same reasons as the Miller claim
Whether Veal preserved a Georgia constitutional claim	Veal: Mentioned Georgia Constitution in enumerations	State: Not applicable	Court: Claim abandoned for failure to brief or cite authority

Miller v. Alabama, 567 U.S. 460 (2012) (mandatory LWOP for juveniles violates Eighth Amendment absent individualized consideration)
Montgomery v. Louisiana, 136 S. Ct. 718 (2016) (Miller announced a substantive rule requiring individualized sentencing determinations for juvenile LWOP)
Graham v. Florida, 560 U.S. 48 (2010) (Eighth Amendment bars LWOP for juveniles convicted of nonhomicide offenses)
Veal v. State, 298 Ga. 691 (2016) (Georgia Supreme Court vacated Veal’s original LWOP sentence and remanded for resentencing under Miller)