Part II more fully unpacks the central jurisprudential values that animate Graham and Miller. By reference to these values, Part III explains how Graham and Miller may be reconciled with Harmelin and Ewing. Finally, Part IV discusses the application of Graham and Miller to one particular category of adult offenders – those sentenced under the three-strikes provision of 21 U.S.C. § 841(b)(1)(A) – and concludes that at least some of these offenders may have viable Eighth Amendment claims
Michael M. O'Hear,
Not Just Kid Stuff - Extending Graham and Miller to Adults,
78 Mo. L. Rev.
Available at: https://scholarship.law.missouri.edu/mlr/vol78/iss4/6