People v. Reyes
63 N.E.3d 884
| Ill. | 2016Background
- Zachary A. Reyes, age 16 at the time, was convicted of first‑degree murder and two counts of attempted murder for a December 20, 2009 multiple‑shooting; jury found him guilty.
- Trial court imposed mandatory statutory sentences plus mandatory firearm enhancements, resulting in a 97‑year aggregate term with earliest release eligibility after 89 years (effectively life).
- Reyes argued his mandatory, aggregate term was a de facto life‑without‑parole sentence and therefore unconstitutional under Miller v. Alabama.
- The appellate court affirmed, rejecting extension of Miller to de facto life terms created by consecutive mandatory sentences.
- The Illinois Supreme Court granted review, agreed Miller’s rationale applies to mandatory term‑of‑years sentences that are the functional equivalent of life without parole, and found Reyes’s sentence unconstitutional.
- The court vacated the sentence and remanded for resentencing under the post‑appeal juvenile sentencing statute (730 ILCS 5/5‑4.5‑105), which allows judicial discretion over firearm enhancements and requires consideration of youth‑related mitigating factors.
Issues
| Issue | People's Argument | Reyes's Argument | Held |
|---|---|---|---|
| Whether Miller applies to a mandatory aggregate term of years that is the functional equivalent of life without parole | Miller applies only to actual life‑without‑parole sentences; consecutive mandatory terms do not trigger Miller | Miller applies when mandatory aggregate terms make release impossible; such de facto life terms are unconstitutional for juveniles | Miller extends to mandatory term‑of‑years sentences that are the functional equivalent of life without parole; Reyes's 97‑year term is unconstitutional |
| Appropriate remedy after vacatur | Resentencing under existing law (State conceded defendant entitled to benefit of newer law if favorable) | Vacatur and resentencing under juvenile‑specific statutory scheme enacted during appeal | Vacate sentence and remand for resentencing under 730 ILCS 5/5‑4.5‑105 (new juvenile sentencing scheme) |
| Whether defendant entitled to sentencing under the statute enacted after offense but before resentencing | State conceded defendant may be sentenced under the new statute | Reyes sought application of the new statute to avoid mandatory enhancements | Court applied Statute on Statutes and remanded for resentencing under 5‑4.5‑105 |
| Whether, under the new statute, the court may decline firearm enhancements | State acknowledged new statute gives discretion | Reyes argued new statute provides relief from mandatory enhancements | Court directed resentencing under statute which permits trial court discretion to decline firearm enhancements |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life without parole for juveniles unconstitutional; individualized youth‑aware sentencing required)
- Roper v. Simmons, 543 U.S. 551 (2005) (juveniles are categorically different for death‑penalty purposes)
- Graham v. Florida, 560 U.S. 48 (2010) (juveniles cannot be sentenced to life without parole for nonhomicide offenses)
- Bear Cloud v. State, 334 P.3d 132 (Wyo. 2014) (applied Miller to aggregate term that functionally equaled life without parole)
- Moore v. Biter, 725 F.3d 1184 (9th Cir. 2013) (held a lengthy aggregate term unconstitutional under Miller)
- State v. Null, 836 N.W.2d 41 (Iowa 2013) (Miller applies where aggregate sentence is functional equivalent of life)
- People v. Caballero, 282 P.3d 291 (Cal. 2012) (applied Miller to lengthy aggregate juvenile sentence)