To punish youths with the same severity as adults and to then make those sentences mandatory - taking away any discretion to weigh each offender individually - fails to consider that difference or the potential for rehabilitation, the court said in determining that no-release sentences are unconstitutional for all but the rare juvenile whose crimes reflect "permanent incorrigibility".
While many states grapple with a U.S. Supreme Court ruling that bans mandatory life-without-parole sentences for juveniles, that's not an issue for Hawaii.
But an Associated Press review has found the gate of freedom slow to open, including in Oregon. The Supreme Court has yet to rule on whether lengthy alternative sentences to life without parole are constitutional, Marsha Levick of the national Juvenile Law Center said, but she believes those cases eventually will be taken up.
Court records show OR still has five men serving true-life sentences for crimes committed as minors.
Five Nevada juveniles who were sentenced for murder have been released since lawmakers ended "Life without parole", for juvenile offenders. The most prominent is Thurston High School shooter Kip Kinkel.
The Missouri Supreme Court.
Flowers was resentenced earlier this year to two concurrent sentences of life with the possibility of parole, meaning he can seek parole after 30 years.
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In other states, dozens of offenders have been resentenced and some paroled, but Tennessee so far is not offering resentencing to its 13 juvenile life-without-parole inmates.
Three of the 38 have been resentenced to terms ranging from 30 to 40 years.
No juvenile offender has ever been sentenced to life without parole in NY, but civil liberties groups have argued that denying parole to offenders with long sentences can amount to the same thing.
The Missouri Supreme Court continues to sort out such cases.
Since the law was changed, 14 juvenile offenders serving life have been resentenced.
Records show Ira is among 103 New Mexico inmates sentenced to 20 years or more for crimes they committed as juveniles. The appeals court left his sentence in place.