Defendant was convicted of first-degree murder, concealment of a homicidal death, and obstruction of justice and sentenced to 36 years. Defendant filed a pro se post-conviction petition focused on changes to the Post-Conviction Hearing Act that gave inmates the right to present a claim based on post-partum depression and post-partum psychosis. The trial court dismissed the petition at the second stage and defendant appealed. The appellate court reversed and remanded for further proceedings, finding the trial court erroneously construed the statutory definition of post-partum depression as limiting its existence to one year past the last child’s birthday and that the statutory definitions did not indicate an intent by the legislature to place temporal limits on the condition. (O’BRIEN and DAUGHERITY, concurring)
Illinois Appellate Court
Criminal Court
Post-Conviction Hearing Act