People v. Jones, 2021 IL 126432

In 1999–2000 petitioner Robert Christopher Jones, age 16–17, was charged with multiple felonies including two counts of first‑degree murder; he confessed to stabbing an elderly couple.
In 2000 Jones entered a fully negotiated guilty plea (age 17) to one murder, two armed robberies, and residential burglary and received concurrent terms, including a 50‑year sentence for murder; he waived a presentence report and mitigation/aggravation hearing.
Jones did not timely withdraw the plea; his initial postconviction petition was denied, and later a successive postconviction petition argued his 50‑year term was a de facto life sentence violative of Miller v. Alabama.
Trial court denied leave to file the successive petition; the appellate court affirmed, reasoning the negotiated plea waived Miller claims and Buffer (2019 IL 122327) later established that >40 years is de facto life.
On further review this Court considered whether a juvenile’s negotiated plea precludes a Miller challenge and whether Miller-based relief would be available; the Court affirmed the appellate court, holding the plea waived the claim and Miller did not apply.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a juvenile’s fully negotiated guilty plea bars a Miller challenge to a de facto life sentence	Jones: plea cannot bar Miller claim because the sentence was later recognized as de facto life and Miller protections must apply to juveniles who pled guilty	State: a voluntary, knowing plea waives non‑jurisdictional constitutional claims; plea was accepted by court exercising discretion, so Miller is inapplicable	Court: Held plea waived Miller challenge; defendant knowingly accepted plea and court’s acceptance was discretionary, so Miller does not apply
If Miller applies, what remedy is appropriate	Jones: if valid, he would be entitled to relief under Miller/Buffer (resentencing or consideration of youth)	State: not reached because Miller claim is waived	Court: did not reach remedy issue because Miller claim found not cognizable

Miller v. Alabama, 567 U.S. 460 (juveniles cannot be subject to mandatory life‑without‑parole; sentencer must be able to consider youth and mitigating circumstances)
Jones v. Mississippi, 593 U.S. (2021) (juveniles may receive discretionary life sentences so long as appropriate procedural safeguards are available)
Brady v. United States, 397 U.S. 742 (1970) (a voluntary, intelligent guilty plea generally waives later objections based on changes in law)
People v. Buffer, 2019 IL 122327 (Illinois: sentences exceeding 40 years for juvenile offenders are de facto life for Miller analysis)
People v. Holman, 2017 IL 120655 (Miller protections apply to discretionary life sentences for juveniles)
People v. Sophanavong, 2020 IL 124337 (voluntary guilty plea waives non‑jurisdictional constitutional claims)
Dingle v. Stevenson, 840 F.3d 171 (4th Cir. 2016) (applies Brady reasoning to a juvenile who pled to avoid a capital sentence)