People v. Buffer

Defendant, age 16 at time of offense, was convicted of 4 counts of 1st degree murder and was found to have personally discharged a firearm that caused the victim's death; he was sentenced to 50 years. A juvenile defendant's prison term is long enough to be considered de facto life without parole at 40 years. Circuit court failed to consider Defendant's youth and its attendant characteristics in imposing sentence, and thus sentence violates 8th amendment. Remanded for resentencing in accordance with Section 5-4.5-105 of Unified Code of Corrections. (KARMEIER, THOMAS, KILBRIDE, GARMAN, and THEIS, concurring; BURKE, specially concurring.)