Croft v. Williams

Ct. of Appeals denied defendant’s motion seeking leave to file second habeas petition that challenged his natural life without possibility of parole sentence on his murder conviction, even though defendant committed said murder at age 17, and Supreme Ct. subsequently held in Miller, 132 S.Ct. 2455, that 8th Amendment forbids sentences of mandatory life in prison without possibility of parole for juvenile offenders. While various Courts of Appeal are split as to whether Miller applies retroactively to defendant’s case, holding in Miller does not apply to defendant’s sentence, where his life sentence was discretionary (as opposed to mandatory) under Illinois law.