People v. Franklin

Illinois Appellate Court
Criminal Court
Sentencing
Citation
Case Number: 
2020 IL App (1st) 171628
Decision Date: 
Wednesday, September 30, 2020
District: 
1st Dist.
Division/County: 
Cook Co., 4th Div.
Holding: 
Reversed and remanded.
Justice: 
GORDON

Defendant, was convicted, after bench trial, of 1st degree murder of his 6-month-old son, and sentenced to natural life imprisonment. Assistant medical examiner testified that some of the baby's injuries were newer and others were more remote in time. Defendant was 18 years and 5 months old when infant died. After his arrest, Defendant was diagnosed with a nonspecific psychosis. Mental health issues may lower a defendant's functional age. Court gave no consideration to Defendant's age except for determining that it qualified him for death-penalty consideration. Defendant made a sufficient legal and factual showing for his petition to be filed. Remanded to allow court to consider whether Defendant's mental and other issues at time of offense rendered him functionally under age 18 or whether, as applied to him, his sentence violates proportionate penalties clause. (LAMPKIN, concurring; BURKE, dissenting.)