Illinois Appellate Court
Criminal Court
Juvenile Sentencing
Defendant, age 17 at time of offenses, was convicted, after jury trial, of various offenses, including 2 counts of 1st-degree murder, and sentenced to aggregate 75 years. Statutory sentencing scheme in place at time of sentencing required court to impose a mandatory de facto life sentence. The framework for sentencing juveniles has markedly evolved since then. Sentencing judge must judge must use the Miller factors to evaluate evidence at the new sentencing hearing to determine whether defendant is “among the rarest of juvenile offenders whose conduct places him [or her] beyond the possibility of rehabilitation." (BIRKETT and ZENOFF, concurring.)