The Ohio Supreme Court has ruled that the 2012 U.S. Supreme Court ruling in Miller v. Alabama applies to discretionary sentences and that the youth of the person involved must be considered when a child is facing a possible sentence of life in prison without the possibility of parole. The court held in State v. Long that the sentencing court record must separately and explicitly reflect exactly how the court considered the person’s youth as a mitigating factor in determining that a life without parole sentence is justified.