Illinois Appellate Court
Criminal Court
Sentencing
Defendant appealed from the circuit court’s second-stage dismissal of his postconviction petition. On appeal, defendant argued that his petition made a substantial showing that his sentence was unconstitutional as applied to him based on his youth and attendance characteristics. The appellate court affirmed in part, reversed in part, and remanded, finding that the question of whether defendant’s sentence violated the proportionate penalties clause depends on multiple factors requiring an evidentiary hearing. (HOLDRIDGE and DAVENPORT, concurring)