People v. Reyes
2015 IL App (2d) 120471
Ill. App. Ct.2015Background
- In December 2009, then-16-year-old Zachary Reyes shot and killed Jason Ventura and shot at two others; Reyes was indicted on multiple counts including first-degree murder and two counts of attempted murder with a firearm.
- A jury convicted Reyes of first-degree murder (personal discharge) and two counts of attempted murder (personal discharge).
- At sentencing, Reyes received the statutory minimums plus mandatory firearm enhancements and consecutive terms, yielding a 97-year aggregate sentence (must serve ~89 years before MSR eligibility).
- Reyes appealed, arguing (1) the Juvenile Court Act’s automatic transfer (excluded jurisdiction) statute is unconstitutional under the Eighth Amendment and Illinois proportionate-penalties clause, (2) it violates federal and state due process, and (3) his 97-year aggregate term is a de facto life-without-parole sentence forbidden by Miller v. Alabama.
- The Second District reviewed statutory constitutionality de novo, considered controlling U.S. Supreme Court precedents (Roper, Graham, Miller) and Illinois Supreme Court precedent (People v. Patterson), and affirmed the conviction and sentence.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Reyes) | Held |
|---|---|---|---|
| Whether the automatic-transfer (excluded-jurisdiction) statute violates the Eighth Amendment or Illinois proportionate-penalties clause | Statute sets forum, not a sentencing scheme; it does not itself punish and therefore does not trigger Eighth Amendment/proportionate-penalties scrutiny | The statute forces juveniles into adult sentencing without individualized consideration of youth, violating Eighth Amendment and Illinois proportions clause | Rejected. Court followed People v. Patterson: the statute is a forum-selection mechanism, not a punitive sentencing statute, so Eighth/proportionate-penalties challenge fails |
| Whether the automatic-transfer statute violates federal or state due process | Prior Illinois precedent upholds statute; it provides permissible legislative classification and procedures | On its face it denies due process by forbidding individualized judicial inquiry into whether adult prosecution/sentencing is appropriate for juveniles | Rejected. Patterson and earlier Illinois decisions control; Roper/Graham/Miller do not undermine the due-process rulings in J.S. and M.A. |
| Whether Reyes’s 97‑year aggregate term is a de facto mandatory life-without-parole sentence forbidden by Miller | State: aggregate term-of-years for multiple convictions and victims is constitutionally permissible and distinct from a mandatory life-without-parole sentence imposed for a single conviction | The aggregated 97-year term (with truth-in-sentencing -> MSR eligibility at ~age 105) is functionally equivalent to life without parole and violates Miller because the court had no chance to consider youth-based mitigating factors | Rejected. Court declined to extend Miller to multi-count aggregated term-of-years sentences; Miller applies to mandatory life-without-parole schemes, not consecutive fixed-term sentences for multiple convictions |
Key Cases Cited
- Roper v. Simmons, 543 U.S. 551 (2005) (forbids capital punishment for offenders who were juveniles at the time of their crimes)
- Graham v. Florida, 560 U.S. 48 (2010) (forbids life without parole for juvenile nonhomicide offenders)
- Miller v. Alabama, 567 U.S. 460 (2012) (holds mandatory life-without-parole for juvenile homicide offenders unconstitutional; requires individualized youth-based sentencing consideration)
- People v. Patterson, 2014 IL 115102 (Ill. 2014) (Illinois Supreme Court: automatic-transfer statute is constitutional under Eighth Amendment, proportionate-penalties clause, and due process; statute is nonpunitive forum-selection provision)
- People v. Thomas, 150 Cal. Rptr. 3d 361 (Cal. Ct. App. 2012) (recognized an aggregate term-of-years as the functional equivalent of life without parole and remanded under Miller — cited by defendant but not adopted by this court)