April 9th, in United States v. Grant, No. 16-3820, the Third Circuit extended the holding in Miller v. Alabama, 567 U.S. 460 (2012) (holding that only incorrigible juvenile homicide offenders who have no capacity to reform may be sentenced to life in prison without the possibility of parole; otherwise, a non-incorrigible juvenile offender must have a “meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation”) to de facto life sentences – that is, a sentence (in years) that meets or exceeds the life expectancy of a juvenile offender. In this case, the sentence was for 65 years, which might make him eligible for release no earlier than at age 72. The court characterized its holding as an “incremental step in the constitutional discourse over the unique protections that the Eighth Amendment affords to juvenile homicide offenders.” The court noted that its holding has been adopted by the Seventh, Ninth, and Tenth Circuits, but acknowledged a contrary holding from the Eighth Circuit.