People v. House

This case presents question as to whether trial court properly dismissed defendant’s petition for post-conviction relief, alleging, among other things, that his mandatory natural life sentence on two murder charges violated proportionate penalties clause of Illinois Constitution. Appellate Court, in considering defendant’s sentence in light of Harris, 2016 IL App (1^st) 141744, found that defendant was entitled to new sentencing hearing, where Appellate Court found that defendant’s mandatory natural life sentence “shocked the moral conscience of the community,” where: (1) defendant was only 19 years old at time of commission of instant murders, was convicted under accountability theory, had no prior violent criminal history and received instant sentence without consideration of instant mitigation factors. As such, Appellate Court found that mandatory natural life sentencing statute was unconstitutional as applied to defendant. In its petition for leave to appeal, govt. argued that Appellate Court’s decision conflicted with Harris, because defendant had not developed record on whether evolving science on juvenile maturity and brain development applied to individuals over age 18.