Illinois Appellate Court
Criminal Court
Sentencing
Defendant was convicted of first-degree murder, attempted first-degree murder, and attempted armed robbery and sentenced to a total of 80 years’ imprisonment. Defendant appealed the summary dismissal of his post-conviction petition, contending that his sentence was an as-applied violation of the proportionate penalties clause because he was 18 years old at the time of the offense. The appellate court affirmed, finding the defendant did not meet his burden of alleging facts showing that his particular circumstances fell under Miller. (PIERCE, concurring and MIKVA, dissenting)