In testimony before the House Judiciary Committee concerning the cross-filed House Bill, a retired circuit court judge noted that the federal Constitution requires that juvenile offenders have “a meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation” and opined that the bill would “alleviate that constitutional problem” and bring “Maryland into conformance with what the Supreme Court has mandated and what other states have already done.” Testimony of Gary Bair on January 21, 2021, concerning House Bill 409 (2021), available at https://tinyurl.com/5xr5pn6f at 4:35:23. Testimony by other advocates for the bill, such as the Campaign for Fair Sentencing of Youth and the Maryland Catholic Conference, also equated the legislation with the standards set by the Supreme Court in
Graham, Miller, and Montgomery.
Farmer v. State, 281 A.3d 834, 851 (Md. 2022)