People v. Williams

This case presents question as to whether trial court properly dismissed defendant’s motion for leave to file third successive post-conviction petition that challenged his life sentence without parole, where defendant argued that his life sentence violated both 8th Amendment of U.S. Constitution and proportionate-penalties clause of Illinois Constitution. While trial court found that defendant had failed to allege actual innocence or demonstrate cause or prejudice to justify filing of third successive petition, Appellate Court, in reversing trial court, found that defendant established sufficient cause and prejudice so as to allow filing of third successive petition, where: (1) defendant could not have raised instant sentencing issue in his prior petition because Miller, which addressed defendant’s sentencing issue, had not been made retroactive prior to defendant’s prior petitions; and (2) defendant, who was 19 years old at time of charged offenses, made prima facie showing of prejudice, where he alleged numerous issues regarding his upbringing, trauma involving his mother’s death, gang influences in his life and his rehabilitation progress in prison that should have been considered by trial court when imposing instant sentence. In its petition for leave to appeal, State argued that there were conflicts within Appellate Court with respect to constitutionality and finality of young adult sentences and with respect to cause and prejudice standards for filing successive post-conviction petitions.