Carter v. State
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At issue was three crimes that were committed when each of three Petitioners was a juvenile and whether each Petitioner was effectively serving a sentence of life without parole because the laws of Maryland do not provide him with a “meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation.” See Graham v. Florida, 560 U.S. 48 (2010).
None of the sentences imposed in these cases was explicitly “life without parole.” In all three cases each Petitioner filed a motion to correct an illegal sentence. The Court of Appeals concluded that one Petitioner was entitled to be resentenced to a legal sentence, holding (1) with respect to the two Petitioners serving life sentences, their sentences are legal under the laws governing parole of inmates serving life sentences in Maryland; but (2) with respect to the Petitioner serving a 100-year sentence, the sentence is effectively a sentence of life without parole in violation of the Eighth Amendment.
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