People v. Campbell

Defendant, who was 17 years old at the time of the offenses, was convicted of first-degree murder and armed robbery and was sentenced to 140 years in prison. The appellate court previously vacated his sentence and he was re-sentenced in 2009 to 110 years in prison. Defendant subsequently sought leave to file a successive post-conviction petition challenging his sentence under Miller. The trial court denied leave and defendant appealed. The appellate court reversed, finding that the minimum sentence that was available at the time of re-sentencing was a de facto life sentence and, as a result, the trial court not have provided the constitutionally-required exercise of discretion. (C.A. WALKER and TAILOR, concurring)