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147) In cither case, the Court--having spoken in Miller, Graham, and Roper--should prompt one of these to occur; the societal and constitutional cutoffs of juvenileness at the very least implicitly, if not explicitly, rest at eighteen.
Though Miller, Graham, and Roper concerned serious crimes and sentences, (149) the Court did not qualify its language in holding eighteen as the cutoff for the definition of juvenileness under the Eighth Amendment.
155) A nationally consistent definition of juvenileness could begin to provide that uniformity and guidance, initiating the movement for creating a better system.