This educational guide is based on the linked primary sources. It is not a Court publication, is not affiliated with the Court, and is not legal advice.
In brief
Overview
According to Petitioner (Bryan Stevenson), petitioner argues that challenges to a sentence can be brought at any time under Florida Rule 3.850.
Background and question before the Court
According to Petitioner (Bryan Stevenson), joe Sullivan was 13 years of age when he was arrested with two older boys, convicted of sexual assault, and sentenced to life without parole.
He is one of only two children this age who have ever been sentenced to life without parole for a non‑homicide offense, and no child has received such a sentence for non‑homicide in the past 18 years.
According to Mr. Stevenson, petitioner asks the Court to adopt a rule that bans life without parole for any child under the age of 14.
What each side argues
Petitioner
According to Mr. Stevenson, petitioner argues that life without parole for children under 14 should be prohibited.
Respondent
According to Petitioner (Mr. Makar), respondent contends that Rule 3.850(b)(2) is consistently and regularly applied.
What happened at oral argument
Oral argument was presented by respondent counsel Scott D. Makar.
Justice Alito asked the petitioner to specify the categorical rule they wish the Court to adopt.
What the Court decided
Why it matters
Joe Sullivan is one of only two children sentenced to life without parole for a non‑homicide offense, highlighting the rarity of such sentences for juveniles.
Terms to know
No glossary terms are available for this guide.
Primary sources
Read the source materials on the official site or open the immutable repository copy used for this guide.
- d5250f26cc592db30f74-r1-dd9ec30a59879ca7.pdforal argument transcript
Guide generated September 23, 2026. Automated validation accepted this version.