People v. Buffer (April 2019)
At 16 years old, Dimitiri Buffer was sentenced to 25 years for a murder conviction and 25 years for a mandatory firearm enhancement. Buffer filed a post-conviction petition, arguing his 50-year prison sentence was unconstitutional because it violated his Eighth Amendment rights. The Illinois Supreme Court determined over 40 years constitutes a de facto life sentence and ordered Buffer be resentenced. A de facto sentence, also known as a virtual life sentence, refers to non-life sentences so long that the individual will likely die or live out a significant portion of their lives incarcerated before release.