People v. Coty

This case presents question as to whether trial court properly sentenced defendant, who is mentally disabled, to 50-year term of incarceration on predatory criminal sexual assault of minor charge, where defendant had prior conviction for aggravated criminal assault. Appellate Court, in remanding matter for new sentencing hearing, found that said sentence violated proportionate penalties clause of Ill. Constitution, where: (1) said sentence was effectively de facto life sentence; (2) trial court lacked information about state of defendant’s intellectual disability at time of sentencing or about whether defendant’s cognitive ability to comprehend consequences of his actions had changed in his 10 years of current incarceration; and (3) trial court lacked facts to determine whether defendant could be restored to useful citizenship. In its petition for leave to appeal, State argued that Appellate Court improperly barred trial court from applying legislatively mandated de jure or de facto natural life sentence to intellectually disabled offenders based on their prior criminal history.