People v. Daniels

Defendant, age 18 at time of offenses, confessed that several days earlier he had sexually assaulted and murdered a woman in Grant Park. Defendant pled guilty to 1st degree murder in exchange for a sentencing recommendation by the State of natural-life imprisonment. Defendant did not and could not have known at the time of his guilty plea that he could argue his natural-life sentence was constitutionally disproportionate as applied to him. Thus, Defendant did not knowingly waive his right to bring an as-applied proportionate penalties claim. Thus, court erred in denying Defendant's motion for leave to file a successive postconviction petition. (CUNNINGHAM and CONNORS, concurring.)