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People v. Reyes - 2016 IL 119271, 407 Ill. Dec. 452, 63 N.E.3d 884

Rule:

A mandatory term-of-years sentence that cannot be served in one lifetime has the same practical effect on a juvenile defendant's life as would an actual mandatory sentence of life without parole—in either situation, the juvenile will die in prison. Miller makes clear that a juvenile may not be sentenced to a mandatory, unsurvivable prison term without first considering in mitigation his youth, immaturity, and potential for rehabilitation.

Facts:

On Dec. 20, 2009, defendant Z.A.R. personally discharged a firearm in the direction of a vehicle occupied by Jason Ventura, Eduardo Gaytan, and Jorge Ruiz—this resulted to the death Ventura as well as serious injury to Gaytan. Z.A.R., who was 16 years old at the time of the shootings, was prosecuted as an adult. Following a jury trial in Illinois state court, he was found guilty of the charged offenses. At his sentencing hearing, the trial court imposed the mandatory minimum sentence of 45 years' imprisonment for the first degree murder conviction. The court also sentenced him to 26 years' imprisonment for each of the two attempted murder convictions. In addition, the trial court determined that, pursuant to section 5-8-4(d)(1) of the Unified Code of Corrections (730 ILCS 5/5-8-4(d)(1) (West 2008)), all of his sentences were required to run consecutively to each other. As a result, Z.A.R. was sentenced to a mandatory minimum aggregate sentence of 97 years' imprisonment. Further, in light of the truth in sentencing statute (730 ILCS 5/3-6-3(a)(2)(i)-(ii) (West 2008)), he was required to serve a minimum of 89 years of the 97-year sentence imposed before he would be eligible for release. Z.A.R. appealed, arguing that his sentence was unconstitutional pursuant to Miller v. Alabama. In Miller, the Supreme Court of the United States held that the eighth amendment to the United States Constitution barred a sentencing scheme that mandated life in prison without possibility of parole for juvenile offenders. The appellate court rejected the argument. Z.A.R. sought review, again arguing that he received a de facto mandatory life sentence without the possibility of parole and that such a sentence was unconstitutional under Miller.

Issue:

Was Z.A.R.'s sentence a de facto mandatory life sentence, and therefore, unconstitutional under the doctrine enunciated by Miller v. Alabama?

Answer:

Yes.

Conclusion:

According to the state supreme court, a mandatory term-of-years sentence that cannot be served in one lifetime has the same practical effect on a juvenile defendant's life as would an actual mandatory sentence of life without parole—in either situation, the juvenile will die in prison. The court averred that Miller made it clear that a juvenile may not be sentenced to a mandatory, unsurvivable prison term without first considering in mitigation his youth, immaturity, and potential for rehabilitation. The court reversed the lower courts' decisions and remanded the matter to the trial court for resentencing.

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