The Graham case originated out of Florida's Juvenile Justice Act of 1994, which permitted the easy transfer of juvenile
offenders to adult criminal courts and “gave judges discretion to impose either juvenile or adult sanctions in
some cases.” [FN32] Florida Attorney General McCollum described this law as part of a multi-decade effort by states
all across the country to increase criminal penalties, thereby “deter[ring] serious crime[].” [FN33] According to Mc-
Collum, these “deliberate and focused strategies worked” because violent crime rates by juveniles declined significantly
from their peak in 1993. [FN34] McCollum's claim that harsh juvenile sanctions effectively deterred juvenile
crime accounted for a substantial portion of the State of Florida's legal justification for JLWOP.”