his own governorship before achieving results in 2020. Under reform signed by Northam that year, all Fishback inmates still incarcerated became eligible for parole, except for those who had been convicted of a Class 1 felony or the sexual abuse of a minor. By the time Northam signed this bill, the cause of the Fishback inmates had largely won favor among prosecutors in Virginia, according to the Association of Commonwealth's Attorneys. In April of that year, responding to the COVID-19 health pandemic, the Virginia General Assembly adopted an "emergency clause" amendment proposed by Northam to grant parole eligibility to Fishback inmates immediately; new bills are usually enacted on July 1 of each year. Another piece of parole reform enacted by Northam in 2020 concentrates on juvenile offenders. At the start of Northam's governorship, Virginia law denied parole eligibility to nearly all juvenile offenders sentenced as adults after 1995. Only those sentenced under a youthful offender statute still qualified. This put Virginia in conflict with the 2012 U.S. Supreme Court decision in Miller v. Alabama, which ruled that mandatory life sentences without the possibility of parole are an unconstitutional penalty for juvenile offenders. By 2020, several other states had already adjusted their laws to be compliant with Miller. Virginia's refusal to do so before 2020 led The Washington Posts editorial board to write that Virginia had failed during the preceding years to respect the decision. On February 24, 2020, Northam signed bipartisan legislation making all Virginia inmates convicted as juveniles eligible for parole after serving twenty years of their sentences. This made Virginia the 23rd state to prohibit life sentences without the possibility of parole for juvenile offenders. A plan to expand geriatric release was also included in Northam's 2020 agenda for criminal justice reform. Under Virginia law, only prisoners older than sixty who have served at least ten years of their sentences or those older than sixty-five who have served at least five years of their sentences qualify for geriatric release. In 2020, Virginia's legislature considered, but did not pass, a bill backed by Northam that would have created two additional categories of inmates eligible for geriatric release: those older than fifty-five who have served at least fifteen years of their sentences and those older than fifty who have served at least twenty years of their sentences. Before 2020, the Virginia Parole Board could not use terminal illness as a