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129) In Miller, Graham, and Roper, when the Court held that juveniles deserve additional protection under the Eighth Amendment, it used eighteen as the age of juvenileness.
Moreover, because the defendants in Graham and Miller were not even seventeen at the time of their crimes, (131) the Court's holdings in these two cases further support the argument that the Court held eighteen to be the cutoff for the definition of juvenileness.
Also, the Court in Miller, Graham, and Roper spoke of the various defendants in terms of youth and juvenileness, (138) despite the fact that the defendants were classified as adults and tried as such in their respective states.