Sands

BACKGROUND

A. In response to a series of decisions addressing Eighth Amendment limits on juvenile sentencing (see, e.g., Miller v. Alabama (2012) 567 U.S. 460 (Miller); Graham v. Florida (2010) 560 U.S. 48, 75), the Legislature enacted section 3051. (Sen. Bill No. 260 (2013-2014 Reg. Sess.), Stats. 2013, ch. 312, §§ 1, 4; In re Trejo (2017) 10 Cal.App.5th 972, 980-981 & fn. 6.) In its current form, the statute provides an opportunity for release (via youth offender parole hearings) to most persons convicted of crimes committed before the age of 26 in their 15th, 20th, or 25th year of incarceration, depending on the sentence imposed for their “ ‘[c]ontrolling offense.’ ” (§ 3051, subds. (a)(2)(B), (b)(1)-(4).) The Legislature originally “passed [section 3051] explicitly to bring juvenile sentencing into conformity with Graham [and] Miller” as well as decisions from the California Supreme Court. (Franklin, supra, 63 Cal.4th at p. 277.) It also explained that recent developments in neuroscience showed that “youthfulness both lessens a juvenile’s moral culpability and enhances the prospect that, as a youth matures into an adult and neurological development occurs,” such individuals…