Illinois Appellate Court
Criminal Court
Proportionate Penalties Clause
Petitioner was found guilty of two first-degree murders and an attempted third murder and was sentenced to natural life, plus 30 years in prison. He subsequently filed a post-conviction petition alleging that because he was 19 years old at the time of the murders his sentence violated the proportionate-penalties clause because of his status as an “emerging adult” who suffered from mental illness at the time of his crimes. The appellate court affirmed, finding that defendant forfeited his claim by failing to raise it during sentencing and that, even if he had not, a life sentence for a legal adult who was the principal shooter in a premeditated double murder was not arguably unconstitutional. (McBRIDE and HOWSE, concurring)