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For much the same reason, the Court shortly thereafter in Roper v. Simmons declared that the Eighth Amendment prohibited imposing the death penalty for a crime committed as a juvenile.114 Next, the Court carried the Atkins-Roper line of cases beyond the capital punishment realm. In Graham v. Florida, Justice Kennedy explained that "[t]he Court's cases addressing the proportionality of sentences fall within two general classifications. The first involves challenges to the length of term-of-years sentences given all the circumstances of a particular case. The second comprises cases in which the Court implements the proportionality standard by certain categorical restrictions on the death penalty."115 In the first line of cases, the Solem-Harmelin-Ewing line, the Court employs a proportionality standard, and "it has been difficult for the challenger to establish a lack of proportionality."116

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