The Illinois Supreme Court ruled unanimously on March 27 that Miller v. Alabama, which struck down mandatory sentences of life without parole for children, is retroactive and applies to those sentenced prior to the U.S. Supreme Court decision in June 2012.
Relying on federal precedent and other state court decisions that applied federal rules, the court held in People v. Davis that Miller announced a substantive rule and is therefore retroactive. As a result, approximately 100 people currently serving mandatory life without parole for crimes committed as youth will be resentenced.
Addolfo Davis was arrested two months after his 14th birthday and charged as an accomplice in a crime. He was given a mandatory sentence of life without parole and has spent more than two decades in prison.
With this ruling, Illinois continues the momentum among state high courts that have ruled Miller should be applied retroactively. Courts in Texas, Nebraska, Massachusetts, Mississippi, and Iowa have ruled that Miller is retroactive.