People v. Reyes

This case presents question as to whether 97-year sentence on instant murder/attempted murder convictions violated 8th Amendment's prohibition against cruel and unusual punishment, where: (1) defendant was 16 years old at time of offenses; and (2) U.S. Supreme Court in Miller, 132 S.Ct. 2455, found that imposition of mandatory life sentence without possibility of parole on juvenile was unconstitutional. In his petition for leave to appeal, defendant argued that holding in Miller applied to him because he received de facto mandatory life sentence in spite of his juvenile status where he will not be eligible for mandatory supervised release until he is 105 years old. Appellate Court, in affirming defendant’s sentence, found that Miller applied only to death penalty or mandatory life sentences and noted that length of defendant’s sentence was based on multiple convictions concerning series of offenses and victims.