Illinois Appellate Court
Criminal Court
Post-Conviction Hearing Act
Defendant appealed from the circuit court’s dismissal of his successive post-conviction petition at the second stage, arguing that his counsel provided unreasonable assistance by failing to amend his pro se conviction to address potential procedural bars to his claim that his sentence violated Miller v. Alabama. The appellate court affirmed, finding that counsel was not unreasonable where the trial court discussed the procedural bars and correctly found prior precedent precluded defendant’s claim. (McLAREN and SCHOSTOK, concurring)