The United States Supreme Court decision in Graham v. Florida forbade life imprisonment without the possibility of parole for offenders under 18 years old for non-homicidal crimes, considering it as incompatible with the Eight Amendment. In order to reach this decision, the Court created a categorical rule, previously applied only to death penalty cases. Although the authors agree on the lack of proportionality of the punishment imposed on the defendant, the use of a categorical rule is criticized, considering preferable the case-to-case narrow proportionality approach.