People v. Simental

Defendant, age 16 at time of offense, was convicted, after jury trial, under an accountability theory of 1st degree murder in 1991 shooting death of a high-ranking member of a street gang; he was sentenced to 60 years, a de facto life sentence. Until discharged Defendant remains subject to the remainder of the 60-year sentence, which is well over the 40-year benchmark for de facto life sentences as set forth in Illinois Supreme Court's 2019 decision in People v. Buffer. Court, in imposing sentence, was required to first consider Defendant's youth and its attendant characteristics, but failed to do so, noting Defendant's age only in passing a few times. Remanded for new sentencing hearing. (BRIDGES and HUDSON, concurring.)