In this case, the defendant received a discretionary life sentence without parole for conduct occurring when the defendant was 17 years old. The Illinois Supreme Court held that Miller applies to discretionary life sentences as well as those which are mandatory. They also reiterated that a juvenile defendant may be sentenced to life imprisonment without parole only if the trial court determines that the defendant’s conduct
showed irretrievable depravity, permanent incorrigibility, or irreparable corruption beyond the
possibility of rehabilitation. The sentencing court may make that decision only after considering the
defendant’s youth and its attendant characteristics. Those characteristics include, but are not
limited to, the following factors: (1) the juvenile defendant’s chronological age at the time of
the offense and any evidence of his particular immaturity, impetuosity, and failure to
appreciate risks and consequences; (2) the juvenile defendant’s family and home environment;
(3) the juvenile defendant’s degree of participation in the homicide and any evidence of
familial or peer pressures that may have affected him; (4) the juvenile defendant’s
incompetence, including his inability to deal with police officers or prosecutors and his
incapacity to assist his own attorneys; and (5) the juvenile defendant’s prospects for
The Illinois Supreme Court decided that the original sentencing hearing judge dealt with the defendant’s youth enough so that a further resentencing would not be required under Miller.
The case is People v. Holman, 2017 IL 120655.