Illinois Appellate Court
Criminal Court
Sentencing
Post-Conviction Hearing Act
Defendant appealed trial court denial of his motion to file a pro se successive post-conviction petition, which alleged that his 100-year sentence for charges relating to a shooting death and burglary was a de facto life sentence and violated the Eighth Amendment and proportionate penalties clause because he was 20 years old and intellectually disabled at the time of the offense. The appellate court affirmed, finding that the trial judge properly considered the applicable factors in determining the appropriate sentence and that defendant had failed to establish a prima facie claim of prejudice as was required to be granted leave to file a successive petition. (GORDON And ELLIS, concurring)