In 2012, in Miller v. Alabama, the U.S. Supreme Court held that judges and juries can impose an LWOP sentence as long as mitigating factors such as the juvenile's upbringing are taken into account.

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The U.S. Supreme Court in Miller v. Alabama ruled that mandatory life without parole (LWOP) sentences for juveniles are unconstitutional, but judges and juries can still impose LWOP if they consider mitigating factors like the juvenile's background.

In 2012, in Miller V