People v. Rhoades, 115 N.E.3d 1238

Defendant Travis D. Rhoades (adult) was convicted after a bench trial of predatory criminal sexual assault of a child (victim under 13) and aggravated criminal sexual abuse for separate acts occurring 2010–2011.
The charging instrument noted a prior predatory criminal sexual assault conviction from 1998 against a 12‑year‑old; defendant served prison time and received in‑custody sex‑offender treatment before release.
Because of the prior predatory‑assault conviction, section 11‑1.40(b)(2) mandated a sentence of natural life imprisonment for the later predatory‑assault conviction; the trial court imposed that life term plus a consecutive 12‑year term for the other offense.
Defendant appealed solely on the facial constitutionality of the mandatory life term under the Eighth Amendment (and principle of proportionality), arguing that Illinois’s abolition of the death penalty makes mandatory life for a nonhomicide offense grossly disproportionate.
The appellate court reviewed the statutory challenge de novo, noting the heavy presumption of constitutionality and that a statute is facially invalid only if no valid application exists.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 720 ILCS 5/11‑1.40(b)(2) is facially unconstitutional under the Eighth Amendment because it mandates life without parole for a nonhomicide offense after Illinois abolished the death penalty	The statute is constitutional; mandatory life for repeat predatory sexual assault is within Eighth Amendment bounds given the seriousness and recidivism risk	Mandatory natural life for a nonhomicide offense is now grossly disproportionate in light of abolition of the death penalty and evolving standards of decency	Statute is facially constitutional; the mandatory life sentence is not grossly disproportionate and Harmelin/Kennedy’s framework controls

Graham v. Florida, 560 U.S. 48 (proportionality and evolving standards concept central to Eighth Amendment review)
Harmelin v. Michigan, 501 U.S. 957 (Kennedy concurrence supplies controlling proportionality framework; forbids only "extreme" or "grossly disproportionate" noncapital sentences)
Solem v. Helm, 463 U.S. 277 (comparative sentencing analysis discussed but not a rigid test)
People v. Huddleston, 212 Ill. 2d 107 (Illinois Supreme Court upheld mandatory life for repeated predatory sexual assault under state proportionality clause)
People v. Sharpe, 216 Ill. 2d 481 (Illinois abandoned cross‑comparison analysis under state proportionate penalties clause)