Despite the Illinois Supreme Court’s reinstatement of Harris’ sentence, the
conversation surrounding sentencing of young offenders has not ended. By affirming the
Appellate Court’s decision in Buffer, the Illinois Supreme Court might provide the
legislature with further guidance on the tailoring of the upcoming bill. Even if the
upcoming legislation is unsuccessful, the state’s highest court has the chance to provide
clearer rules for lower courts to follow when examining the sentences of the state’s
Emily Hoerner, Illinois Supreme Court: Juvenile Protections Do Not Extend to 18-Year-Olds,
INJUSTICEWATCH (Oct. 18, 2018), https://www.injusticewatch.org/news/2018/illinois-supreme-court-
Emily Hoerner & Jeanne Kuang, 167 Illinois prisoners serving life sentences for crimes committed as
juveniles, CHI. SUN-TIMES (May 6, 2018), https://chicago.suntimes.com/crime/injustice-watch-department-
Emily Hoerner & Jeanne Kuang, Illinois high court to consider how much time is too much for youth crime,
INJUSTICEWATCH (June 4, 2018), https://www.injusticewatch.org/news/2018/illinois-supreme-court-to-
Emily Hoerner & Jeanne Kuang, Less than life, INJUSTICEWATCH (May 6, 2018),
Josh Rovner, Policy Brief: Juvenile Life Without Parole, THE SENTENCING PROJECT (Oct. 2017),
McKinley v. Butler, 809 F.3d 908 (7th Cir. 2016).
Miller v. Alabama, 132 S. Ct. 2455 (2012).
People v. Buffer, 75 N.E.3d 470 (Ill. App. Ct. 2017).
People v. Harris, 70 N.E.3d 127 (Ill. App. Ct. 2017).
People v. Harris, No. 121932, 2018 IL 121932 (Ill. 2018).
S.B. 3228, 100th Gen. Assemb. (Ill. 2018).