State v. Spencer

Illinois Supreme Court held that an aggregate 100-year prison sentence for a defendant who was 20 when the crimes occurred is not a de facto life sentence because a state statute makes first-degree murder defendants under 21 eligible for parole after 20 years and mandates that the reviewing board consider mitigating circumstances related to the defendant’s youth. The court further held that the the fact the sentence is not de facto life does not foreclose the defendant from bringing an as-applied challenge to his sentence under the state constitution’s “proportionate penalties” clause in a post-conviction petition.