Whether Missouri's decision to order resentencing for juvenile homicide offenders with mandatory 50-year sentences but not for Joshua, a juvenile homicide offender sentenced to mandatory life without parole, violates equal-protection

QUESTIONS PRESENTED Joshua Wolf has been serving an unconstitutional sentence since he was sentenced to mandatory life without parole for a homicide offense committed when he was just sixteen years old. Although Missouri has ordered resentencing for other unconstitutional mandatory sentences imposed upon juvenile offenders, it has not ordered resentencing for Joshua. The questions presented are: 1. Does the State of Missouri’s decision that resentencing is required for juvenile homicide offenders sentenced to mandatory 50 year sentences but not for Joshua, a juvenile homicide offender sentenced to mandatory life without parole, contrary to or an unreasonable application of this Court’s equal protection jurisprudence as set forth most clearly in Plyler v. Doe? 2. Was the State of Missouri’s decision that the Sixth, Eighth and Fourteenth Amendments do not require a constitutionally compliant sentencing hearing for a juvenile offender sentenced to an unconstitutional mandatory life without parole sentence contrary to this Court’s decisions in Miller v. Alabama, Mempa v. Rhay, and an unreasonable application of Montgomery v. Louisiana? 3. Did the Eighth Circuit unreasonably impose an improper and unreasonable standard for a Certificate of Appealability in contravention of Buck v. Davis, and Miller-El v. Cockrell when it refused to issue a Certificate of Appealability to Joshua, despite circuit precedent requiring resentencing when a sentence is unconstitutional, and deepening the circuit split on the proper relief for juvenile offenders subject to cruel and unusual mandatory sentences that violate the Eighth and Fourteenth Amendments? ii