Lawton v. State
Annotate this CaseIn this case, the Third District Court of Appeal read Graham v. Florida as creating a homicide-case exception to the categorical rule against sentencing a juvenile offender to life without parole for a nonhomicide crime. The court’s reading would permit a juvenile to be sentenced to life without parole for a nonhomicide offense if the juvenile also committed a homicide in the same criminal episode. Applying this homicide-case exception, the Third District held that Defendant’s life-without-parole sentences for certain nonhomicide offenses committed as a juvenile were constitutional under Graham because Defendant also committed a homicide in the same criminal episode. The Supreme Court quashed the Third District’s decision, holding that Graham’s categorical rule leaves no room for the homicide-case exception recognized by the state’s Second, Third, and Fourth District Courts of Appeal. Remanded with instructions that Lawton be resentenced for the nonhomicide offenses of attempted first-degree murder with a firearm and armed robbery with a firearm.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.