Where a juvenile defendant entered a negotiated guilty plea and received a 40-year or more sentence prior to Miller v. Alabama holding that life sentences for juveniles are unconstitutional, the defendant did not waive his right to challenge his sentence as unconstitutional because all waivers must be knowing and prior to Miller the defendant could not have been aware of the right he was waiving.The 3rd District Appellate Court reversed and remanded a decision from 10th Judicial Circuit Judge Michael D. Risinger.Philip …