This report discusses a recent ruling by the U.S. Court of Appeals for the Third Circuit in the case of "United States v. Grant" that prohibits the use of "de facto" life sentences without possibility of parole (created by sentencing juveniles to prison terms longer than the average lifespan or that would end after they reached the typical retirement age) for juvenile offenders who have a reasonable potential for rehabilitation. The report also discusses previous decisions related to this issue and the split among appeals court over the proper application of the Eighth Amendment to juvenile sentencing restrictions.