People v. Reyes, 2016 IL 119271

Zachary Reyes, age 16 at the time, was convicted of first‑degree murder and two counts of attempted murder for a shooting that killed Jason Ventura and injured others.
Prosecuted as an adult, Reyes received statutorily mandatory terms: 45 years for murder (20 years + 25‑year firearm enhancement) and 26 years each for two attempted murders (6 years + 20‑year firearm enhancements), ordered to run consecutively.
The aggregate mandatory minimum sentence was 97 years, with earliest parole eligibility after 89 years—effectively ensuring Reyes would remain imprisoned for life.
On appeal Reyes argued, under Miller v. Alabama, that a mandatory de facto life sentence for a juvenile is unconstitutional because it forecloses individualized youthful‑offender mitigation.
The Illinois Supreme Court held that a mandatory term‑of‑years that is the functional equivalent of life without parole violates the Eighth Amendment and vacated Reyes’s sentence. The case was remanded for resentencing under the then‑new juvenile sentencing statute (730 ILCS 5/5‑4.5‑105), which allows sentencing discretion regarding firearm enhancements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a mandatory aggregate term of years that cannot be served in a lifetime (a de facto life without parole) violates the Eighth Amendment for juvenile offenders	The State: Miller applies only to actual statutory life without parole sentences, not to consecutive term‑of‑years aggregates	Reyes: Miller’s prohibition extends to mandatory term‑of‑years sentences that functionally guarantee death in prison because they eliminate individualized consideration of youth	The court held that a mandatory term‑of‑years that is the functional equivalent of life without parole for a juvenile violates the Eighth Amendment (Miller applies)

Miller v. Alabama, 567 U.S. _ (2012) (mandatory life without parole for juveniles unconstitutional; requires individualized sentencing)
Roper v. Simmons, 543 U.S. 551 (2005) (death penalty unconstitutional for offenders under 18)
Graham v. Florida, 560 U.S. 48 (2010) (life without parole unconstitutional for nonhomicide juvenile offenses)
Moore v. Biter, 725 F.3d 1184 (9th Cir. 2013) (very long aggregate sentence for juvenile found unconstitutional as functional life term)
People v. Caballero, 282 P.3d 291 (Cal. 2012) (Miller applies to de facto life terms resulting from aggregate sentences)