People v. House

Defendant, age 19 and 2 months at time of offense, was convicted, after jury trial, of 2 counts of 1st degree murder and 2 counts of aggravated kidnapping based on his participation int eh 1993 abductions and shooting deaths of a 15-year-old victim and an 18-year-old victim. Defendant was sentenced to a mandatory natural life term for the murder convictions and 60 years for each aggravated kidnapping conviction, to run consecutively to the life term. Appellate court erroneously help that Defendant's sentence of natural life violated proportionate penalties clause of Illinois Constitution as applied to him without a developed evidentiary record or factual findings on the as-applied constitutional challenge.  Remanded for 2nd-stage postconviction proceedings. Vacatur of appellate court's judgment as to actual innocence is warranted in light of intervening Illinois Supreme Court decisions in 2016 and 2020 which reviewed 2nd-stage dismissal of actual innocence claims premised on recantation. (GARMAN, THEIS, and NEVILLE, concurring; A. BURKE, concurring in part and dissenting in part; M. BURKE and OVERSTREET, concurring in part and dissenting in part.)