People v. Brown

Defendant, age 19 at time of incident, was convicted, after jury trial, on accountability theory of two counts of first degree murder, and sentenced to mandatory natural life in prison without possibility of parole. Educational psychology/special education expert testified that Defendant's IQ was in range of persons with mental retardation, and that Miranda warnings were given at level higher than Defendant's level of understanding, per test results. Videotape showed that Defendant knowingly and intelligently waived his Miranda rights prior to giving videotaped statement. Sentence is not unconstitutionally disproportionate; statutorily mandated sentencing practice of these circumstances is not unconstitutional. (HOFFMAN and KARNEZIS, concurring.)