People v. Holman, 2017 IL 120655 (2017) – Defendant, age 17 at the time of the crime, challenged denial of his motion for permission to file a successive post-conviction petition challenging his discretionary sentence to life without parole for murder. He sought a new sentencing hearing. The Illinois Supreme Court confirmed that Miller applies to discretionary LWOP sentences like defendant’s. It reasoned that “none of what the [Miller] Court said is specific to only mandatory life sentences,” as Montgomery made clear. Indeed, the Supreme Court’s “far-reaching commentary about the diminished culpability of juvenile defendants . . . is neither crime- nor sentence-specific. . . . Miller and Montgomery send an unequivocal message: Life sentences, whether mandatory or discretionary, for juvenile defendants are disproportionate and violate the eighth amendment, unless the trial court considers youth and its attendant characteristics.” Nonetheless, the court agreed with the lower courts that defendant’s original (pre-Miller) sentencing hearing complied with Miller and, thus, affirmed denial of post-conviction relief.