Illinois Appellate Court
Criminal Court
Post-Conviction Hearing Act
Defendant was convicted of first-degree murder and appealed from a trial court order denying him leave to file a successive post-conviction petition arguing that his life sentence violated the proportionate penalties clause because he was 20 years old at the time of the offense. The appellate court affirmed, finding that the proportionate penalties claim was forfeited. (McBRIDE and BURKE, concurring)