Illinois Appellate Court
Criminal Court
Juvenile Sentencing
Defendant, age 17 at time of offense, filed pro se postconviction alleging that his 45-year sentence (mandatory minimum for 1st degree murder) is unconstitutional. He had pled guilty to 1 count of 1st degree murder and 1 count of aggravated battery with a firearm. In light of Illinois Supreme Court's 2019 People v. Buffer decision, the 45-year sentence is a de facto life sentence which violates the 8th amendment. Remanded to trial court for resentencing, as trial court did not have occasion to consider Defendant's youth and its attendant characteristics. (DELORT and ROCHFORD, concurring.)