Whether consecutive sentences for non-homicide offenses that effectively result in life without parole for a juvenile offender violate the Eighth Amendment

QUESTIONS PRESENTED 1. Whether Graham v. Florida, 560 U.S. 48 (2010), applies with the equal force to consecutive sentences for non-homicide offenses that work in the aggregate to foreclose the possibility of parole during a juvenile’s lifetime as it does to “life without parole” sentences. 2. Even if Graham does not apply, whether Miller v. Alabama, 567 U.S. 460 (2012), provides any protection to juveniles facing such sentences for non-homicide offenses. 3. In the alternative, whether, in assessing gross disproportionality, a court should review the cumulative effect of the sentences imposed rather than each sentence in isolation. Harmelin v. Michigan, 501 U.S. 957 (1991). i