People v. Leanos

Defendant, who was 18 years old at the time of the offense, was found guilty of first-degree murder and sentenced to a total of 45 years in prison. On appeal, defendant argued that his Miranda waiver was not valid and that the trial court erred when it did not consider the constitutionality of defendant’s sentence due to his age. The appellate court affirmed, finding that the waiver was valid and that trial counsel did not properly raise an as-applied challenge. The court further noted that the defendant could raise the constitutional argument in a post-conviction petition. (HOWSE and COBBS, concurring)