People v. Reyes, 162 N.E.3d 302

In 2009, then-16-year-old Zachary Reyes was convicted of first-degree murder and two counts of attempted murder for shooting into a vehicle; he was prosecuted as an adult.
Original sentencing produced a 97-year aggregate mandatory minimum (consecutive mandatory terms and firearm enhancements); Illinois Supreme Court later held that aggregate term was a de facto life-without-parole sentence and vacated it (People v. Reyes) and remanded for resentencing under the new juvenile-sentencing framework.
On remand the court obtained updated PSI and psychological testing (noting ADHD, low-average intellectual functioning, gang involvement, remorse, program certificates, and a medium recidivism risk in the LSI-R); the defendant had admitted in an affidavit that he fired the shots.
At resentencing the court stated it considered statutory mitigation/aggravation and the Miller factors but did not explicitly address the defendant's immaturity, impulsivity, or the PSI finding of medium recidivism risk or his institutional programming and expressions of remorse.
The court sentenced Reyes to an aggregate 66 years (deemed a de facto life term for a juvenile), making him parole-eligible after about 63.5 years; Reyes appealed.
The appellate court vacated and remanded, holding the trial court failed to make the requisite Miller-based findings (i.e., whether Reyes is among the rare juvenile offenders beyond rehabilitation) before imposing a de facto life sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court adequately considered Miller factors before imposing a de facto life aggregate sentence	State: trial court considered age, family, participation, rehabilitation; disciplinary reports and gang affiliation show risk and lack of amenability to rehabilitation	Reyes: court failed to meaningfully consider youth-related characteristics (immaturity, impulsivity) or weigh evidence of rehabilitation and medium recidivism risk	Vacated and remanded — trial court did not make the necessary Miller/Holman findings that Reyes is beyond rehabilitation before imposing de facto life
Whether the sentencing claim was forfeited for not filing a postsentencing motion	State: waived forfeiture and asked appellate court to decide merits	Reyes: claim preserved for review on appeal	Forfeiture waived by State; court reached merits
Whether Miller applies to de facto term-of-years sentences for juveniles	State implicitly addressed merits; appellate precedents treat de facto life like LWOP for juveniles	Reyes: 66-year term is a de facto life sentence subject to Miller protections	Court: 66-year aggregate is a discretionary de facto life sentence and Miller applies; sentencing must address Miller factors

Miller v. Alabama, 567 U.S. 460 (2012) (Eighth Amendment forbids mandatory LWOP for juveniles; courts must consider youth and attendant characteristics)
Montgomery v. Louisiana, 136 S. Ct. 718 (2016) (Miller is retroactive; only rare juveniles whose crimes reflect irreparable corruption may receive LWOP)
People v. Reyes, 2016 IL 119271 (Ill. 2016) (Illinois Supreme Court: aggregate term can be a de facto life sentence and must comply with Miller)
People v. Holman, 2017 IL 120655 (Ill. 2017) (articulates Miller factors and requires trial courts to determine whether juvenile is beyond possibility of rehabilitation)
People v. Buffer, 2019 IL 122327 (Ill. 2019) (defines de facto life for juvenile as a sentence greater than 40 years)