The HJOA subjects 'habitual juvenile offenders' to mandatory incarceration until the age of 21. The act defines habitual juvenile offenders as those with three adjudications of delinquency. The first two adjudications must be for offenses that would be felonies if committed by an adult. The third adjudication must involve a felony for which a juvenile may be tried as an adult. In addition to upholding the incarceration of a 13-year-old for two adjudications of delinquency, the court in People v. J. A. held that an 8-year imprisonment for a habitual juvenile offender was not cruel and unusual punishment. In its decision the court misapplied the plain-meaning rule, a doctrine of statutory interpretation, in its reading of the HJOA. The court's analysis of cruel and unusual punishment was incomplete and inconsistent with the U.S. Supreme Court's decision in Solem v. Helm (1983), which mandates proportionality in sentencing. The decision also conflicts with the underlying policies of the juvenile court system. It will promote sentence disparity in juvenile adjudications, and the emphasis on protecting society obstructs the rehabilitative philosophy of the juvenile court system. 139 footnotes.