Ms. Falcon was sentenced to life in prison without the possibility of parole in 1999 for the murder of Richard Todd Phillips, which Ms. Falcon committed when she was 15 years old. The U.S. Supreme Court recently ruled that juveniles convicted of murder cannot be mandatorily sentenced to life in prison without the possibility of parole under the ban on cruel and unusual punishment in the Eighth Amendment. Based on that 2012 decision, Ms. Falcon filed a motion seeking to vacate her sentence. The trial court denied her motion and the First District Court of Appeal upheld that ruling.