People v. Hilliard

Defendant, age 18 at time of offense, was convicted, after jury trial, of attempted murder and aggravated battery with a firearm and sentenced to 15 years plus a mandatory 25-year firearm enhancement. Only natural or de facto life sentences require consideration of youth and its attendant characteristics. As Defendant did not receive the most severe penalty possible, the procedural protections under Miller v. Alabama were not required. The sentence was not "cruel, degrading, or so wholly disproportionate to the offense as to shock the moral sense of the community. Because Defendant did not state the gist of a constitutional claim, summary dismissal of his 1st stage postconviction petition was proper. (HOWSE and LAVIN, concurring.)