730 ILCS 5\5-8-1(C) Illinois Mandatory Natural Life Sentencing Statute
In People v. Miller, 202 Ill. 2d 328, 781 N.E.2d 300, 269 Ill. Dec. 503 (2002), our supreme court found that the mandatory natural life sentencing statute, section 5-8-1 of the Unified Code of Corrections (730 ILCS 5/5-8-1(a)(1)(c)(ii) (West 2002)), was unconstitutional as applied to the Miller defendant. Miller, 202 Ill. 2d at 341.
In Miller, the defendant was 15 years old and had "one minute to contemplate his decision to participate in the incident and stand as a lookout during the shooting, but never handled the gun." Miller, 202 Ill. 2d at 341.
Following the shooting, the Miller defendant ran to his girlfriend's house. Miller, 202 Ill. 2d at 331.
The Miller defendant was charged with two counts of first-degree murder (720 ILCS 5/9-1(a)(1) (West 1996)) based on accountability (720 ILCS 5/5-2(c) (West 1996)) and transferred to adult criminal court pursuant to section 5-4(6)(a) of the Juvenile Court Act of 1987 (705 ILCS 405/5-4(6)(a) (West 1996)). Miller, 202 Ill. 2d at 340.
The Miller defendant was convicted of both counts and sentenced to 50 years' imprisonment after the trial court found that section 5-8-1 was unconstitutional as applied to him.
On direct appeal, our supreme court agreed that the sentence, as applied to the Miller defendant, was unconstitutionally disproportionate. Miller, 202 Ill. 2d at 341.
Our supreme court's fording was based upon the convergence of the accountability statute, the transfer statute, and the mandatory sentencing statute, combined with the fact that the Miller, defendant was "the least culpable offender imaginable." Miller, 202 Ill. 2d at 341.