People v. Davis

This case presents question as to whether U.S. Supreme Court’s decision in Miller v. Alabama, 132 S.Ct. 2455, applied retroactively so as to require new sentencing hearing where defendant received natural life sentence on his two murder convictions at time when defendant was juvenile. In Miller, Court found that natural life sentence for juvenile, who had been found guilty of murder, could constitute cruel and unusual punishment under certain circumstances, and Appellate Court found, in response to trial court’s denial of defendant’s motion seeking leave to file successive post-conviction motion that raised instant 8th Amendment issue with respect to his sentence, that Miller applied retroactively due to fact that Miller decision was “watershed rule of criminal procedure.” As such, defendant was entitled to new sentencing hearing to allow trial court to consider factors regarding defendant’s youth that could potentially reduce instant natural life sentence to lesser sentence.