People v. Roberts CA4/3

DISCUSSION

On appeal, Roberts argues the exclusion from YOPHs of young adult offenders sentenced to LWOP violates equal protection under the United States and California Constitutions. He also asserts this exclusion and his LWOP sentence violate the prohibitions on cruel and/or unusual punishment in the United States and California Constitutions. We disagree. A. Overview of Section 3051 We begin by providing a brief overview of section 3051, which has been written about extensively by courts. (See, e.g., People v. Hardin (2024) 15 Cal.5th 834, 842-846 (Hardin); People v. Acosta (2021) 60 Cal.App.5th 769, 775-777 (Acosta).) In 2013, the Legislature enacted section 3051 “in response to a series of decisions concerning Eighth Amendment limitations on juvenile sentencing.” (Acosta, supra, 60 Cal.App.5th at p. 775; see also Graham v. Florida (2010) 560 U.S. 48, 82 (Graham) [concluding the Eighth Amendment “prohibits the imposition of [an LWOP] sentence on a juvenile offender who did not commit homicide”]; Miller v. Alabama (2012) 567 U.S. 460, 465

3 (Miller) [concluding the Eighth Amendment prohibits a mandatory LWOP sentence for a juvenile offender]; People v. Caballero (2012) 55…