People v. Miles

This case presents question as to whether trial court properly sentenced defendant to 6.5-year term of incarceration on burglary charge, where said sentence was based on finding that defendant’s criminal history qualified him for Class X treatment. Appellate Court, in vacating defendant’s sentence, found that defendant did not qualify for Class X treatment, because: (1) although defendant had two prior Class 2 or greater criminal convictions, his 2005 conviction concerned conduct that occurred at time he was 15 years old; and (2) said conviction could not support imposition of Class X sentence, where, had defendant committed his 2005 offense under laws in effect at time of instant 2016 burglary, said offense would have led to juvenile adjudication instead of Class 2 felony conviction. In its petition for leave to appeal, State argued that: (1) there is no distinction between convictions rendered while defendant was juvenile and those that occur after defendant is no longer subject to authority of juvenile court; and (2) amendments to Juvenile Court Act do not apply retroactively to cases already completed.