Defendant was found guilty of first-degree murder of five victims and was sentenced to a mandatory term of natural life in prison. Defendant filed a post-conviction petition in which he argued that his sentence violated his rights under the proportionate penalties clause because he was 22 years old at the time that he committed the offenses. The trial court summarily dismissed the petition and the appellate court affirmed the trial court order. The supreme court also affirmed, finding that defendant’s post-conviction petition failed to allege any facts specific to his circumstances other than age that would have supported an arguable basis that there was a violation of the proportionate penalties clause as applied to the defendant. (THEIS, NEVILLE, OVERSTREET, and O’BRIEN, concurring and CUNNINGHAM, specially concurring. HOLDER WHITE took no part in the decision)
Illinois Supreme Court
Criminal Court
Proportionate Penalties Clause