People v. Harris, 2018 IL 121932

Darien Harris (age 18y3m at offense) was convicted at bench trial of first-degree murder, attempted first-degree murder, and aggravated battery with a firearm for a gas-station shooting; trial court relied heavily on eyewitness Saffold and other identifications.
Sentenced to mandatory, enhanced terms that produced an aggregate mandatory-minimum term of 76 years.
On direct appeal the appellate court: affirmed convictions, corrected mittimus to one attempted-murder conviction, and vacated the sentence as violating the Illinois Constitution’s proportionate-penalties (rehabilitation) clause; remanded for resentencing.
Illinois Supreme Court: affirmed sufficiency of the evidence, reversed the appellate court’s vacation of sentence on Illinois constitutional grounds (holding defendant’s as-applied challenge premature), and rejected defendant’s federal Eighth Amendment facial challenge to extend Miller to ages under 21.
The Court held defendant failed to develop the evidentiary record needed for an as-applied Illinois-constitution challenge and explained that Miller/Roper/Graham draw the juvenile/adult categorical line at age 18 for federal Eighth Amendment purposes.

Issue	State/People's Argument	Harris's Argument	Held
Sufficiency of evidence for murder	Eyewitness IDs (Saffold, Ronald Moore), surveillance corroboration, and other evidence suffice	Argues bullets/calibers and location (Chase Bank) create reasonable doubt / second-shooter theory	Conviction affirmed — evidence sufficient when viewed in light most favorable to prosecution
Whether aggregate 76-yr mandatory sentence violates Illinois proportionate-penalties clause (as-applied)	Forfeiture and inadequate development of record; appellate court erred to decide as-applied claim without evidentiary hearing	Claims mandatory de facto life for a young adult (18) shocks moral sense; invokes Miller line of reasoning	As-applied claim premature for lack of developed record; appellate court’s resentencing order reversed
Whether sentence violates Eighth Amendment by extending Miller to ages <21 (facial)	Supreme/legislative line at 18; federal cases limit Miller to <18; research inconclusive	Urges extension of Miller/Graham/Roper to young adults up to 21 based on neuroscience	Facial Eighth Amendment claim rejected — Court declines to extend Miller beyond under-18 line
Remedy / procedural route for youth-based Eighth/Illinois claims	Trial/postconviction proceedings are proper fora to develop facts for as-applied claims	Asked remand for evidentiary hearing or relief on direct appeal	Court declines remand with retained jurisdiction; suggests postconviction or other proceedings to develop record

Roper v. Simmons, 543 U.S. 551 (juveniles categorically ineligible for death penalty)
Graham v. Florida, 560 U.S. 48 (categorical bar on life-without-parole for juvenile nonhomicide offenders)
Miller v. Alabama, 567 U.S. 460 (categorical bar on mandatory life-without-parole for juvenile homicide offenders)
Jackson v. Virginia, 443 U.S. 307 (standard for appellate review of sufficiency of the evidence)
People v. Thompson, 2015 IL 118151 (requirement to develop record for as-applied constitutional challenges)
People v. Holman, 2017 IL 120655 (narrow exception where Miller claim can be resolved on the record)