People v. Ybarra, 67 N.E.3d 404

In February 2009, Martin Ybarra (age 20 at the time) was tried and convicted by a jury of three counts of first‑degree murder for the February 20, 2009 shootings that killed Kendrick Pitts (17), Johnny Edwards (13), and Raheem Washington (15).
Multiple eyewitnesses placed Ybarra at the scene firing a rifle from a car; eyewitnesses identified him in a photo array and lineup. Physical evidence included the recovered rifle with an incomplete DNA profile that did not exclude Ybarra.
Ybarra admitted connections to Latin Kings gang members; sister and a cohabitant gave statements admitting movement of the rifle but later recanted at trial claiming police coercion; those prior statements were admitted.
At sentencing the State relied on victim impact statements; defense submitted a mitigation packet describing Ybarra’s disadvantaged childhood, low IQ/developmental disabilities, lead exposure, and other adverse factors.
Ybarra was sentenced to mandatory natural life under 730 ILCS 5/5‑8‑1(a)(1)(c)(ii) (multiple murders by a person 17 or older). He argued on appeal that the mandatory sentence violated the Illinois Constitution’s proportionate‑penalties clause because it prevented consideration of mitigation and any prospect of restoration to useful citizenship.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the mandatory natural‑life sentence for multiple murders (730 ILCS 5/5‑8‑1(a)(1)(c)(ii)) violates the Illinois Constitution’s proportionate‑penalties clause as applied to Ybarra	The State argued the statute is constitutional as applied; legislature considered gravity of multiple murders and rehabilitation prospects when mandating life.	Ybarra argued the mandatory life term is disproportionate given his youthfulness, mitigating background (low IQ, poverty, lead exposure, abusive home), and that the statute prevented meaningful consideration of mitigation or chance for restoration.	Affirmed — the court held the mandatory life term did not shock the moral sense of the community as applied to Ybarra, who was the shooter who executed three teenagers; the trial court had reviewed mitigating evidence and stated it would have imposed life even if discretion existed.

Roper v. Simmons, 543 U.S. 551 (prohibits death penalty for juvenile offenders)
Graham v. Florida, 560 U.S. 48 (bars life without parole for juveniles for nonhomicide offenses)
Miller v. Alabama, 567 U.S. 460 (mandatory life without parole for juveniles violates Eighth Amendment; sentencing authority must consider youth/mitigation)
People v. Miller, 202 Ill. 2d 328 (discusses Illinois proportionate‑penalties clause and review forms of proportionality)